Code of ethics - Nunziante Magrone Studio Legale Associato

Introduction

Nunziante Magrone Studio Legale Associato (the “Firm”) conducts its business in accordance with the principles of loyalty, integrity, independence, professionalism, and responsibility, and strives for excellence in the areas in which it operates.

This Code of Ethics is intended to serve as a point of reference for all the Firm’s stakeholders, laying out the principles and rules of conduct with which every employee and professional working within or with the Firm must comply in the practice of their work activities and profession, as well as all the commitments undertaken by the Firm toward all parties with whom it interacts in the course of its business activities.

The adoption of this Code of Ethics has the purpose of promoting ethical and transparent conduct, also with the aim of strengthening the trust that clients, institutions, and the wider community place in the Firm.

1. General Provisions

This Code of Ethics lays out the principles and rules of conduct with which every employee and professional working within or with the Firm must comply in the practice of their work activities and profession. It is not meant, however, to replace the independent judgment and common sense that every professional and employee must exercise in their work and in their relations with others.

The Code of Ethics applies to all partners, collaborators, consultants, and employees of the Firm, to anyone operating in the name of or on behalf of the Firm, and to the Firm’s suppliers (the “Recipients“). All Recipients must comply with the principles and rules of conduct contained herein, including the principles of loyalty, integrity, independence, professionalism and responsibility, in order to ensure excellent service in compliance with applicable laws and regulations.

The Code of Ethics is supplemented by other internal policies that the Firm has adopted or will adopt (hereby incorporated by reference) and which may be viewed and copied from the relevant section of the Firm’s intranet (intra.nmlex.it) for collaborators, consultants, and employees of the Firm, and/or the Firm’s website (www.nunziantemagrone.it) for suppliers.

The Firm reserves the right to periodically update the Code of Ethics in order to align it with regulatory developments, best professional practices, and changing needs.

2. Principles and Rules of Conduct

The Firm requires all Recipients to comply with the highest ethical standards as well as with the rules laid out in the professional codes of conduct established by professional associations, so that all activities are carried out with fairness and lawfulness and protect the interests of clients and the community.

The fundamental values with which all Recipients must comply include:

Lawfulness: all Recipients must carry out their professional or work activities honestly and in compliance with current laws and regulations, as well as applicable rules;

Integrity and professionalism: partners, collaborators, and consultants of the Firm must operate with the utmost honesty and fairness, avoiding any behaviour that could compromise clients’ trust or harm the Firm’s image. All professional activities must be carried out with expertise, continuous development and dedication, ensuring the highest level of protection of clients’ interests;
Solidarity: the Firm promotes mutual respect, collaboration, and support among colleagues, fostering a harmonious and inclusive work environment, also with a view to achieving professional and personal growth objectives;
Respect for others and gender equality: all Recipients must treat clients, colleagues, counterparties, and collaborators with courtesy and respect. Respect is demonstrated through the appreciation of diversity, the ability to listen, and a willingness to engage in constructive dialogue, while avoiding any form of favouritism, discrimination, harassment, or behaviour that undermines the dignity of others for reasons of gender, ethnicity, religion, political or union affiliation, language, age, or disability;
Confidentiality and data protection: the Firm guarantees the confidentiality of information acquired in the course of professional activity, in compliance with current laws governing the protection of personal data (GDPR and national legislation). The unauthorised disclosure of confidential information is prohibited. Recipients must adopt appropriate measures to protect sensitive data. The Firm’s partners, collaborators, and consultants are bound by strict professional secrecy regarding work performed, information received from clients, and ideas and discussions arising in any organisational area within the Firm;
Independence: the Firm’s partners, collaborators and consultants, in carrying out their professional activities, must preserve their independence and assert their freedom from pressure or influence of any kind, including personal interests;
Conflicts of interest: the Firm’s partners, collaborators and consultants must avoid situations of conflict of interest that could compromise their impartiality and independence or otherwise violate professional codes of conduct. In the event of conflict, even merely potential, the Firm’s partners, collaborators, and consultants must promptly notify the Firm’s Management Committee, which will assess the appropriate measures to manage the situation. The Firm’s partners, collaborators, and consultants must comply with the decisions taken by the Firm’s Management Committee. The Firm’s partners, collaborators, and consultants are prohibited from carrying out activities that may even only potentially compete with those of the Firm, as well as from using information, regarding the Firm or its clients, obtained during the course of their collaboration.

3. Internal Relations

3.1 Relations with Professionals and/or Employees

The Firm recognises the value and fundamental contribution of the attorneys, collaborators, and employees who operate within its organisation. Relations with these individuals are based on the principles of transparency, fairness, respect, and enhancement of professional skills.

Selection and onboarding: the Firm guarantees selection processes based exclusively on merit, expertise, and compliance with the Firm’s ethical and professional values;
Fair and dignified treatment: all of the Firm’s partners, collaborators, consultants, and employees must be treated with respect and consideration, avoiding any form of discrimination based on gender, ethnicity, religion, sexual orientation, disability, or other personal characteristics;
Opportunities for growth and career advancement: the Firm promotes the continuous development of skills of its partners, collaborators, consultants, and employees, encouraging professional training and continuous learning in their respective fields. In addition, it offers career opportunities based on merit, without any form of discrimination;
Dialogue: the Firm considers constructive dialogue and active listening as essential elements for fostering a peaceful, cohesive, productive, and collaborative work environment. All of the Firm’s partners, collaborators, consultants, and employees are encouraged to communicate in a clear and respectful manner, fostering open dialogue when it comes to professional and organisational matters. Respect for the opinions of others, a willingness to listen and the ability to receive feedback are essential qualities for continuous improvement and for building strong and harmonious professional relationships;
Collaboration: the Firm promotes an integrated and multi-disciplinary approach to the profession, encouraging collaboration between different professional figures and between various practices. The objective is to guarantee clients receive comprehensive and effective assistance, fully leveraging skills and specialisations within the Firm. Internal collaboration and cohesion are strategic values that enable timely, effective, and personalised responses to client needs, strengthening the Firm’s reputation and the quality of the services it provides;
Ongoing professional training: the Firm recognises the importance of ongoing training and professional development in order to ensure high standards of expertise and quality in the services provided. The Firm is committed to ensuring that its partners, collaborators, consultants, and employees are offered ongoing training, aimed at improving technical, ethical, and managerial skills. To this end, the Firm promotes:

i) participation in professional refresher courses, conferences, seminars, and workshops in legal and interdisciplinary fields;

ii) the organisation of internal training and refresher sessions on professionally relevant topics;

iii) access to legal databases, digital libraries, and other information resources to support self-teaching and research;

iv) collaboration with universities and academic institutions to promote advanced and specialised training programs.

Study leave: the Firm recognises the possibility of requesting time off or leaves of absence for educational purposes, subject to compatibility with organisational and professional requirements. This opportunity is intended to give attorneys and collaborators the chance to earn specialisations, master’s degrees, or other professional and/or academic qualifications without hindering their professional growth within the Firm;
Parenthood: among the various measures aimed at supporting parenthood and care of the family, the Firm recognises maternity leave, paternity leave, family leave, and leave for a child’s illness;
Work-life balance: the Firm recognises the importance of an adequate work-life balance, encouraging organisational arrangements that allow for sustainable management of the workload. The Firm is committed to fostering a culture that respects personal time, insofar as compatible with operational and professional requirements.

3.2 Use of Corporate Assets and IT Systems

The Firm provides its members with the tools and resources necessary to perform their professional activities. The use of such assets must comply with the following principles:

Responsible use: the Firm’s assets, including IT systems, telephones, offices, and office supplies, must be used exclusively for work-related purposes, avoiding any unauthorised improper or personal use;
Use of IT systems: electronic devices, software, and company networks must be used in compliance with internal regulations governing data protection and security. All individuals are required to exercise the utmost care and attention in order to prevent threats to the integrity of the Firm’s IT systems. The installation of unauthorised software or the use of corporate tools for non-professional activity that could compromise the Firm’s security is prohibited. Likewise, browsing websites with inappropriate and/or offensive content is prohibited. Each member of the Firm may access only the IT resources for which they are authorised and are required to safeguard their access credentials in order to prevent external disclosure and improper use;
Maintenance and care: the Firm’s partners, collaborators, consultants, and employees are responsible for the proper preservation and maintenance of the assets entrusted to them by the Firm, avoiding waste or damage resulting from negligence or improper use;
Prohibition of unjustified personal use: taking advantage of the Firm’s assets for personal use is permitted only in exceptional cases and with prior authorisation from the Firm’s Management Committee.

3.3 Health and Safety in the Workplace

The Firm recognises the importance of health and safety in the workplace and is committed to ensuring a safe and healthy working environment that complies with current applicable laws.

The Firm’s partners, collaborators, consultants, and employees must strictly comply with internal policies and industry regulations and are expected to use the Firm’s assets appropriately and safely so as to maintain a working environment that is as safe and healthy as possible.

Professionals and employees are invited to promptly report any accident, dangerous behaviour, or potentially hazardous situations.

3.4 Disclosure Requirements

The Firm adopts a policy of transparency and accountability, which includes compliance with disclosure obligations required by law and professional standards. The Firm’s partners, collaborators, consultants, and employees must provide complete, truthful, and timely information in order to ensure compliance with current laws and professional ethical standards and to safeguard the Firm’s integrity and reputation. In particular, the Firm’s partners, collaborators, and consultants must periodically provide evidence of their membership to relevant professional associations, payment of registration fees, and payment to pension funds. In addition to the provisions of this Code of Ethics regarding conflicts of interest, the Firm’s partners, collaborators, consultants, and employees must notify the Firm’s Management Committee regarding their involvement in any criminal, administrative, or, where relevant, civil proceedings, as well as any other circumstance that could impact compliance with their obligations to the Firm.

4. External Relations

4.1 Relations with Clients

The Firm is committed to providing clients with clear, timely, and effective legal assistance.

The Firm’s partners, collaborators, and consultants must comply with the ethical principles adopted by the Firm in their relations with clients and to ensure protection of clients’ interests with the utmost professional diligence, performing their professional mandate in compliance with the obligations of their engagement and respecting ethical standards.

Communication with clients must be transparent and easy to understand, ensuring that clients are continuously updated on the status of their case. It is essential to maintain a relationship based on trust, loyalty, and mutual respect, and to avoid establishing any economic or commercial relationships with clients that may affect the performance of professional activities in view of the principles of autonomy and independence.

4.2 Relations with Suppliers

The Firm is committed to maintaining transparent, fair, and professional relationships with its suppliers, in compliance with the principles of ethics and lawfulness. The Firm’s suppliers, whether of services or goods, are chosen on the basis of objective criteria of quality, reliability, regulatory compliance, and respect for human rights and environmental rights.

Selection and management of suppliers: the Firm adopts a supplier selection process that ensures the appropriate transparency, based on objective criteria such as the quality and price of the goods or services offered, as well as on guarantees of assistance, efficiency, and availability of resources. It is essential that the selected suppliers meet high qualitative standards and comply with applicable legal and professional regulations. Furthermore, the Firm assesses suppliers’ commitment to sustainability, social responsibility, and compliance with laws governing workers’ rights, as well as their adherence to the principles laid out in this Code of Ethics, reserving the right to terminate the supply contract in the event of violations;
Relations based on trust and collaboration: the Firm must maintain relationships with suppliers based on trust, respect, and collaboration, fostering an environment in which all parties can work in a calm and constructive manner. Engaging in or tolerating improper practices is prohibited. These include actions such as favouring suppliers for personal reasons or establishing relationships that may compromise impartiality in purchasing decisions;
Respect for the environment: the Firm takes an active stance in protecting the environment and positively evaluates those suppliers whose activities are in line with environmental and social sustainability and who adopt specific measures and tools to minimise the negative impact of their operations on the environment;
Conflicts of interest and ethical practices: the Firm is committed to avoiding all conflicts of interest in its relationships with suppliers. Should situations emerge that could compromise independence in purchasing decisions, any of the Firm’s partners, collaborators, consultants, or employees involved must report them promptly. All commercial relationships with the suppliers must be based on principles of honesty, fairness, and lawfulness, in compliance with applicable regulations.

4.3 Relations with Institutions and Counterparties

The Firm operates in full compliance with institutions, judicial authorities, counterparties, and other professional figures. All interactions must be based on fairness, professionalism, and collaboration, avoiding hostile or improper conduct.

4.4 Anti-Corruption

The Firm adopts a zero -tolerance policy towards corruption and any other unlawful or improper practice. It is absolutely prohibited to request or receive payments, kickbacks, gifts, or any other undue benefits or advantages, whether directly or for the Firm. Business courtesies, such as gifts or forms of hospitality, are permitted only when they are of modest value and, in any case, do not compromise the integrity or the reputation of either party and cannot be interpreted as being intended to improperly obtain advantages.

The Firm has internal procedures in place to prevent the risk of unethical behaviour.

4.5 Environmental Sustainability and Social Responsibility

The Firm promotes a responsible and sustainable approach in its activities. The Firm is committed to reducing the environmental impact of its operations by implementing a policy against waste and the improper use of environmental resources, both directly tied to its activities (direct impacts) and resulting from behaviours and activities that are beyond its direct control (indirect impacts). Objectives relating to the issue of environmental protection and sustainability are pursued through the study of effective and innovative solutions, as well as through ongoing initiatives aimed at raising awareness among all members of the Firm regarding the negative impacts of their activities.

The Firm promotes social inclusion practices and supports philanthropic initiatives and collaborations with reputable organisations for the benefit of the community, which align with and contribute to achieving the Sustainable Development Goals.

4.6 Behaviour Outside the Workplace and the Use of Social Networks

All of the Firm’s partners, collaborators, consultants, and employees must conduct themselves in a dignified and responsible manner even outside of office hours. Their actions must not in any way harm the interests, reputation, or identity of the Firm.

The use of private accounts on the various social media networks must be managed with care. In particular:

sharing confidential or sensitive information regarding clients, cases handled, or the Firm’s activities is prohibited;
publishing content that could damage the Firm’s image or compromise clients’ trust is prohibited;
any personal opinion shared on social networks must be kept entirely separate from professional activity, ensuring that any stance that the Firm has not explicitly adopted cannot be implicitly attributed to it;
any type of online interaction that may result in a conflict of interest or a breach of the code of conduct is prohibited.

5 Whistleblowing

Anyone who believes that a violation of the Code of Ethics has occurred may submit a report to Firm’s Management Committee (or to a founding partner of the Firm, if the report concerns a member of the Management Committee). Reports can be submitted in written or verbal form and will be treated with the utmost confidentiality (subject to legal obligations) and without any risk of retaliation for those submitting the report in good faith.

Reports will be reviewed by the Management Committee, which will assess their validity and adopt any sanctions, in accordance with the provisions of the following paragraph. The Management Committee may refer the matter to the partners’ meeting in cases of particular severity (similarly, each of the Firm’s founding partners may refer the matter to the partners’ meeting for issues regarding members of the Management Committee).

6 Measures in Response to Violations

Violations of this Code of Ethics will result in the application of sanctions proportionate to the severity of the violation.

Sanctions will vary among the Firm’s employees, partners, collaborators, and consultants:

for employees (under the applicable National Collective Labour Agreement):
- formal warning, in the case of a minor violation;
- temporary suspension from duties, in the case of a moderately serious violation;
- dismissal, in the most severe or repeated cases.
for partners, collaborators, and consultants:
- formal warning, in the case of a minor violation;
- suspension of the professional engagement, in the case of a moderately serious violation;
- termination of the collaboration or expulsion from the association, in the most severe or repeated cases;
- reporting to the relevant offices of the professional association, if the violations require disciplinary action.

In the event that the violation of the Code of Ethics also constitutes a violation of the law, the Firm reserves the right to report the responsible party to the relevant authorities, in compliance with current laws and procedures provided for by the legal system.

However, in the event that the violation does not involve wilful misconduct, the Firm shall adopt constructive solutions aimed at strengthening the individual’s sensitivity and awareness regarding respect for the values and principles contained in this Code of Ethics.