r39

Owner (by Law responsible) Prof. Massimo Clementi - President

Privacy Statements

With regard to data exchanged, reference is made to Legislative Decree 196/2003, Consolidated Text on Privacy which establishes as: "Anyone has the right to the protection of personal data concerning him". The privacy code aims to ensure citizens a high level of protection regarding the processing of personal data

                                                                                          ETHICAL CODE 

                                                                                        General Principles

1- Compliance with national and international law

R39 srl is committed to guarantee through its own corporate structures, regulations and contracts, reliability and adherence to the applicable national and international laws as well as for its own operational processes. These indications are valid for its own activities and for those of the shareholders for which it exercises the management and coordination role as provided from the article 2359 of the italian civil code.

2- Ethics 

R39 sets as fundamental values the conformity of operational and individual behavior to the ethical principles of correctness, reliability, confidentiality-privacy and equality

3- Correctness and reliability

The behavior of the staff in its entirety must comply with the principles expressed in this regulation in the performance of their duties and comply with the transparency and truthfulness of the information in internal and external company communications. Any communication in the event that it cannot take place directly can take place through the means established by the European Directive on Whistleblowing (2019/1937) 

4- Privacy - Confidentiality

It is important to make confidential use of any information of which one becomes aware by virtue of the positions held and to guarantee this prerogative to employees and Stakeholders through adequate procedures and systems.

5- Reciprocity

Maintain a behavior inspired by autonomy, integrity as well as loyalty and responsibility towards the reference  ecosystem.

6- Equality

Internal - All workers in relation to the tasks assigned and the required objectives must be evaluated with quantitative, qualitative criteria and on assigned objectives. In carrying out the duties, within the limits of good faith and correctness, equal possibilities of achieving the objectives must then be guaranteed, so that fair treatment based on criteria of merit can be established and a corporate culture based on trust and collaboration can be created. The choice of personnel is therefore based on assessments of merit, respect for the value criteria and company objectives, repudiating discriminatory criteria to guarantee respect for equal opportunities.

External - Treat stakeholders according to a logic of respect, recognition and equal dignity, regardless of size and sector, aiming to enhance the distinctive features that enable or facilitate relationships, guaranteing the positive aligned mutual interpretation of the principles .

7- Collaboration

Internal - To Manage organizational issues with company regulations  defined  in general compliance with the category contract models or through variants independently developed in private negotiations and consequently implemented, audited, reported in official periodic corporate managerial or corporate reports.

External - Maintain, with the Stakeholders, a behavior inspired by systemic collaboration in compliance with the roles and functions of the parties.

5-Economic Sustainability of decisions

Operational and extraordinary decisions do not disregard cost-effectiveness criteria, interpreting it not only as profitability but also in a strategic key and as sustainability and medium-long term balance.

6- Approach to decisions

- Identification of own Strategic Assets (Tangible and intangible)

- Innovation and Development

To clarify which operating context, organizational form or product best interprets or abilitate, presently and in the future the optimal expression of up-mentied reference values through the Strategic Assets.

- Compliance with ESG (Environmental - Social - Governance) criteria in assessments

R39 considers the implementation of the ESG principles (Compliancy with EU regulation 2019/2088) in its operating practices and strategic assessments of the short, medium and long term to be fundamental. It also considers it important to implement these principles in such a way as to guarantee cost-effectiveness through the medium- and long-term sustainability of decisions. In fact, if these decisions are well implemented, they are also functional in creating an industrial corporate culture that is also attentive to the medium-term business balance and not just to the short-term one.