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CODE OF ETHICS

CODE OF ETHICS

FOREWORD
JUNGLE’S VISION

Jungle Srl (hereinafter referred to as “JUNGLE” or the “Company”) is aware that the authority of a company is recognized not only by the competence of its collaborators and the high quality of the service provided to customers, but also by the attention paid to the needs of the entire community.

The principles that have always inspired the work of this Company are formally collected in a Code of Ethics of Conduct in the belief that reliability is built daily by respecting standards and valuing people.

This Code of Ethics represents, therefore, a distinctive and identifying element in relation to the market and third parties, the knowledge and sharing of which, required of all those who work in the Company or collaborate with it, constitute the foundation of our activity and the first step to concur in the pursuit of our vision.

Therefore, JUNGLE’s goal is to pursue excellence in the market in which it operates, through Sustainable Development, safeguarding the Environment and the Safety of the people involved through the consistency of behavior that respects Social Ethics, achieve satisfaction and ensure added value for the Employee, for the Customer and, in general, for the Community.

PURPOSE AND ADDRESSEES

This Code of Ethics (hereinafter, the “Code”) illustrates the set of ethical and moral principles that underlie JUNGLE’s activities as well as the lines of conduct adopted by the Company both within its business (in relations between employees and close associates) and externally (in relations with institutions, suppliers, customers, business partners, political and trade union organizations as well as the media – hereinafter, the “Stakeholders”).

Compliance with these principles is of fundamental importance in achieving JUNGLE’s corporate mission and ensuring its reputation in the socio-economic context in which it operates.

Preliminarily, it should be noted that JUNGLE firmly believes that every activity must be carried out ethically, recognizing itself in the principle enshrined in Article 41 of the Italian Constitution, according to which private economic initiative “may not be carried out in conflict with social utility or in such a way as to be detrimental to security, freedom, and human dignity.”

This Code is binding on the directors and employees of JUNGLE, as well as all those who work and collaborate, on a permanent or temporary basis, on behalf of the Company (hereinafter, the “Recipients”).

The Code will be widely disseminated within the internal governance structure, and widely communicated externally, possibly including through its website.

JUNGLE also undertakes to adopt any further provisions so that the principles and requirements of the Code can be timely disseminated and applied.

1 GENERAL PRINCIPLES

The conduct of the Recipients, at all levels of the company, is guided by the principles of legality, fairness, non-discrimination, confidentiality, diligence, and loyalty.

1.1 Legality

JUNGLE operates in absolute compliance with the law and this Code.

All Recipients are therefore required to comply with all applicable regulations and to keep abreast of legislative developments, including by taking advantage of the training opportunities offered by JUNGLE. The Company considers transparency in financial statements and accounting a fundamental principle for the conduct of its business and for the protection of its reputation.

1.2 Fairness

Fairness and moral integrity are an unfailing duty for all Recipients.

Recipients are required not to establish any privileged relationships with third parties that are the result of external solicitations aimed at obtaining improper advantages.

In the performance of their activities, Recipients are required not to accept donations, favors or benefits of any kind (except for items of modest value) and, in general, not to accept any quid pro quo for the purpose of granting improper advantages to third parties.

In turn, the Recipients shall not make donations of money or goods to third parties or otherwise offer illicit benefits or favors of any kind (except objects of modest value or business courtesy gifts authorized by the Company) in connection with the activity they perform for the benefit of JUNGLE.

The intrinsic belief that they are acting in the best interests of the Company does not exempt Recipients from their obligation to observe the rules and principles of this Code punctually.

1.3 Non-Discrimination

In its relations with Stakeholders and in particular in the selection and management of personnel, work organization, choice, selection and management of suppliers, as well as in its relations with Bodies and Institutions, JUNGLE avoids and repudiates any discrimination concerning the age, sex, race, sexual orientation, state of health, political and trade union opinions, religion, culture and nationality of its interlocutors.

At the same time, JUNGLE fosters integration, promoting intercultural dialogue, protection of the rights of minorities and the weak.

1.4 Confidentiality

JUNGLE is committed to ensuring the protection and confidentiality of the personal data of Recipients and Stakeholders, in compliance with all applicable data protection regulations.

The Recipients are required not to use confidential information, learned by reason of their work activity, for purposes unrelated to the exercise of that activity, and in any case to act at all times in compliance with the confidentiality obligations assumed by JUNGLE towards all Stakeholders.

In particular, the Recipients are required to maintain strict confidentiality on documents likely to reveal know-how, transportation information, business information, and corporate transactions.

1.5 Diligence

The relationship between JUNGLE and its employees is based on mutual trust: employees are, therefore, expected to work to further the interests of the Company, in accordance with the values set forth in this Code.

Recipients must refrain from any activity that may constitute a conflict with the interests of JUNGLE by renouncing the pursuit of personal interests that conflict with the legitimate interests of the Company.

In cases where the possibility of the existence of a conflict of interest may be portrayed, the Recipients are required to contact, without delay, their hierarchical superior so that the Company may evaluate, and possibly authorize, the potentially conflicting activity.

In cases of violation, the Company will take all appropriate measures to put an end to the conflict of interest, reserving the right to act for its own protection.

1.6 Loyalty

JUNGLE and the Recipients are committed to fair competition, in compliance with national and EU regulations, in the awareness that virtuous competition is a healthy incentive for processes of innovation and development, and also protects the interests of consumers and the community.

2 RELATIONS WITH EMPLOYEES AND CONTRACTORS
2.1 Personnel selection

The evaluation and selection of personnel are carried out according to fairness and transparency, respecting equal opportunities in order to combine JUNGLE’s needs, with the professional profiles, ambitions and expectations of the candidates.

JUNGLE undertakes to take all useful measures to avoid any form of favoritism in the personnel selection process using objective and meritocratic criteria, respecting the dignity of the candidates as well as in the interest of the good performance of the company.

Hired personnel, including through the implementation of this Code, receive clear and correct information about the roles, responsibilities, rights and duties of the parties.

2.2 Personnel management

JUNGLE protects and enhances its human resources, striving to maintain constant the conditions necessary for the professional growth, knowledge and skills of each person, carrying out appropriate training for professional development and any initiative aimed at pursuing this goal.

JUNGLE promotes workers’ participation in the life of the company, providing participatory tools capable of gathering workers’ opinions and suggestions, ensuring their widest participation.

Without prejudice to the utmost helpfulness to the Company, no worker may be obliged to perform tasks, services or favors that are not due according to his or her employment contract and role in the company.

The Company is firmly committed to combating incidents of bullying, stalking, psychological violence and any behavior that is discriminatory or harmful to the dignity of the person on and off company premises.

Relations between employees must be conducted with loyalty, fairness and mutual respect, in observance of the values of civil coexistence and the freedom of individuals.

3 WORK ENVIRONMENT

JUNGLE is committed to providing its staff with a healthy, safe working environment that respects the dignity of workers.

Safety in the workplace is ensured both by strictly implementing the provisions stipulated by applicable law and by actively promoting a culture of safety through specific training programs. Staff training is a central element of the management system adopted.

JUNGLE protects the health of its workers, while also ensuring compliance with hygiene and preventive health regulations.

4 MANAGEMENT OF THE ENTERPRISE
4.1 Compliance with internal procedures

JUNGLE believes that management efficiency and a culture of control are indispensable elements for achieving its objectives.

Recipients are expected to strictly observe the company’s internal procedures and instructions.

Recipients must act according to their respective authorization profiles and must keep all appropriate records to keep track of actions taken on behalf of the company.

4.2 Accounting management

In accounting management activities, Recipients are required to act in accordance with the principles of truthfulness, accuracy and transparency so that JUNGLE’s reputation is protected both internally and externally.

Adherence to these principles also enables the company to plan its operating strategies according to its true economic and financial situation.

All items reported in the accounts must, therefore, be supported by complete, clear and valid documentation, avoiding any form of omission, falsification and/or irregularity.

In the case of asset or economic items based on valuations and estimates, the related recording must be inspired by criteria of reasonableness and prudence.

4.3 Protection of assets

Recipients exercise their functions by seeking to rationalize and contain the use of corporate resources.

Recipients are required to properly apply security provisions to protect hardware devices from unauthorized access, which could seriously infringe on the data protection rights of JUNGLE’s personnel and customers.

4.4 Communication

JUNGLE ensures that appropriate communication tools are made available to Stakeholders through which they can interact with the company to make requests, seek clarification, or make complaints.

JUNGLE promotes effective corporate communication capable of putting the company in contact with civil society in order to acknowledge instances, needs and requirements of the community and to disseminate its values and mission.

Information disseminated to Stakeholders is complete and accurate so that recipients are enabled to make correct and informed decisions.

JUNGLE’s advertising promotion respects ethical values, protecting minors and repudiating vulgar or offensive messages.

4.5 4.5 Sustainable Event Management

JUNGLE, by virtue of the path undertaken regarding the creation and maintenance of a Sustainable Event Management System in line with ISO 20121 certification, is committed to respecting the principles defined in its Sustainability Policy, as outlined below:

  • Integrity, understood as adherence to ethical principles;
  • Transparency, understood as openness regarding decisions and activities that impact society, the economy, and the environment, and the willingness to communicate them clearly, accurately, promptly, honestly, and completely;
  • Inclusion, understood as the practice of fair treatment and involvement of all stakeholders;
  • Sustainable resource management, understood as care and responsibility for sustainable development shared by all those whose actions affect environmental, social, and economic impacts.

By following these principles, JUNGLE therefore pursues a program of continuous improvement designed to involve its key stakeholders, including the supply chain.

Aware of the possible negative impacts of events on the environmental and socio-economic spheres, JUNGLE also commits to evaluating and preventing potential risks, in compliance with regulations and with the human right to a healthy and safe environment for all.

5 EXTERNAL RELATIONS
5.1 Relations with Authorities and Public Administrations

Relations with Authorities and Public Administration must be marked by the utmost clarity, transparency and cooperation, in full compliance with the law and according to the highest moral and professional standards.

The Recipients, unless expressly authorized, may not relate in the name and on behalf of JUNGLE with the Authorities and the Public Administration.

In relations with Public Officials, Persons in Charge of a Public Service, and the Public Administration in general, the Authorized Recipients shall adhere to the highest standards of fairness and integrity, refraining from any form of pressure, explicit or veiled, aimed at obtaining any undue advantage for themselves or for JUNGLE.

In this regard, authorized Recipients will be required to strictly comply with the provisions of this Code, as well as, more generally, with the directives issued by JUNGLE management.

5.2 Relations with political and labor organizations

JUNGLE does not favor or discriminate against any political or trade union organization.

The Company refrains from making any undue contribution in any form whatsoever to parties, trade unions or other social formations, except for specific exceptions and in any case always within the limits of what is permitted by current regulations.

Recipients are required to refrain from any direct, indirect or boastful pressure on political figures or union representatives.

5.3 Relationship with customers and suppliers

Recipients shall deal with third parties with courtesy, competence and professionalism, in the belief that the protection of the company’s image and reputation and consequently the achievement of the company’s objectives depend on their conduct.

In particular, Recipients must refrain from any form of unfair or deceptive behavior that could lead customers or suppliers to rely on unfounded facts or circumstances.

Recipients are expected to make consistent efforts to provide timely and high-quality services to customers, seeking to limit any form of disservice or delay in order to maximize customer satisfaction.

Relations with suppliers are based on loyalty, fairness and transparency.

Suppliers are chosen on the basis of objective criteria of cost-effectiveness, expediency and efficiency.

The selection of suppliers on purely subjective and personal grounds or, in any case, by virtue of conflicting interests with those of the company is precluded.

Recipients must put in place every possible control so that suppliers and customers are also able to comply with the fundamental ethical principles set forth in this Code.

6 INTERNAL CONTROL SYSTEM

Compliance with the requirements of this Code is entrusted to the prudent, reasonable and careful supervision of each of the Recipients, within their respective roles and functions within the company.

All Recipients are encouraged to report facts and circumstances potentially in conflict with the principles and requirements of this Code to their immediate superiors.

JUNGLE’s management and the bodies appointed for this purpose shall take all necessary measures to put an end to violations, being able to resort to any disciplinary measure in compliance with the law and workers’ rights, including trade union rights.

7 GUIDELINES OF THE SANCTIONS SYSTEM

The internal control system is geared towards the adoption of tools and methodologies aimed at countering potential business risks, in order to ensure compliance not only with the law, but also with internal provisions and procedures.

In fact, violation of the principles set forth in the Code and the procedures indicated in the internal controls compromises the fiduciary relationship between the Company and its directors, employees, consultants, collaborators in various capacities, customers, suppliers, business and financial partners.

Such violations will therefore be immediately prosecuted by JUNGLE in an incisive and timely manner through the adoption of appropriate and proportionate disciplinary measures.

The effects of violations of the Code of Ethics and internal protocols must be taken into account by all those who, in any capacity, have dealings with JUNGLE. Depending on the seriousness of the conduct engaged in by the person involved in one of the unlawful activities set forth in the Code, JUNGLE will take appropriate action without delay, regardless of the possible prosecution by the judicial authorities.

Notwithstanding the above, conduct in violation of the Code of Ethics constitutes:

  • serious misconduct for employees (blue-collar workers, white-collar workers, middle managers and executives), with the sanctions, applied depending on the seriousness, provided for in the CCNL for the category (verbal reprimand, written reprimand, fine not exceeding three hours’ pay, suspension from work and pay up to a maximum of three working days, dismissal for just cause or justified reason); in the case of pending criminal prosecution or execution of a measure restricting personal freedom taken against the employee, before adopting the disciplinary measure, the sanction of suspension from work and pay may be adopted, for the duration corresponding to the outcome of the criminal prosecution or until the end of the duration of the measure restricting personal freedom;
  • just cause for revocation of the directors’ mandate;
  • cause for immediate termination of the relationship, in the most serious cases, for external collaborators and para-subordinates;
  • cause for immediate termination of the relationship, in the most serious cases, for suppliers, contractors and subcontractors.

The identification and application of sanctions will always take into account the general principles of proportionality and appropriateness with respect to the violation alleged.

In all the aforementioned cases, JUNGLE also reserves the right to exercise all actions it deems appropriate for compensation for damages suffered as a result of conduct in violation of the Code of Ethics.