Natlive, recognizing the importance of ethical-social responsibility, compliance and environmental protection in the conduct of business, adapts its activities to full compliance with the principles and standards of behavior expressed in this Code of Ethics. It contains a set of principles to which all facilitating activities and behaviors are guided and which must be observed under any and all applicable regulatory provisions.
Natlive intends to combine its goals of business success with the maintenance and development of a relationship of trust with all those who interact with it, including customers, employees, the communities in which the company operates, suppliers and competitors.
- wants to provide its customers with quality and highly innovative solutions and services that are safe and responsive to their needs, at appropriate prices, treating its customers with respect, honesty and transparency;
- wants to pursue the objectives of growth and profit, directing its activities to the priority observance of the principles contained in this Code of Ethical Conduct ("Code");
- is committed to providing its employees with an environment that encourages individual and team excellence and helps Natlive achieve competitive success;
- acts ethically as a responsible party;
- will always compete fairly, honestly, and within the limits established by law and this Code.
The Code is intended to provide general information regarding compliance issues and is not intended to be an exhaustive treatment with respect to the various matters outlined.
Employees must comply with the laws of the country in which they work, which take precedence, where conflicting, over the requirements of the Code.
To enable any professional, institutional or private publisher to disseminate news, promos and other video content via the web, always remaining the exclusive owner of its content and maintaining full control of its distribution and eventual monetization. To become the point of reference for technological innovation in the media and digital sector in the territory and beyond, supporting businesses, associations, professional orders and the challenges they face. To become a reference company first nationally then worldwide with scalable business for: creation, management of secure and inviolable media platforms devoted to multiscreen distribution; management and live streaming distribution of events in complete autonomy by the client.
To accompany our clients in the New Media Era. To interpret technological innovation by making it functional to their needs by offering them the use of reliable and transparent innovative technologies. Provide access to private video content to publishers worldwide, enhancing, through home made productions, the universally famous and appreciated Italian and European uniqueness (places, people, food, fashion, history, etc.). Offer streaming media services of all types that meet the domestic and global management, promotion and comparison needs of companies, institutions, artists, etc.
Art. 1. Compliance and interpretation
1a) Compliance with the ethical principles of the Code.
Natlive's policy is, and always has been, to pursue business activities with honesty and integrity, in accordance with high ethical and moral principles. To ensure full compliance with these principles, the same have been listed in this Code, which applies to Natlive, to all its employees and collaborators, from any nation, and to all employees and collaborators of its subsidiaries and affiliates. Employees and associates of Natlive are asked to acknowledge the Code and attest that they have read and understand it as well as agree with its contents. Each year, selected Managers may be asked to affirm the compliance of their conduct with the principles set forth in this Code.
1b) Enforcement Responsibilities.
Managers at every level are responsible for the communication and effective application of these principles within their respective Organizational Structures.
1c) Responsibility for interpretation.
Should any questions arise regarding the interpretation or application of this Code, employees are required to consult their supervisor.
Art. 2. General principles
In decisions affecting relations with its stakeholders (relations with customers, relations with shareholders, personnel management or labor organization, selection and management of suppliers, relations with the surrounding community and the institutions that represent it), Natlive avoids all forms of discrimination such as, but not limited to, discrimination on the basis of race, color, sex, age, religion, physical condition, marital status, sexual orientation, citizenship, ethnic origin, political opinion, or any other discrimination contrary to law. (made coordinated with item 4l)
Within the scope of their activities, Natlive's collaborators and employees are expected to diligently comply with applicable laws, the Code of Ethics, and internal regulations.
Under no circumstances may the pursuit of Natlive's interest justify dishonest conduct.
2c) Fairness in cases of conflicts of interest.
In any activity, situations must always be avoided where those involved are, or may even appear to be, in conflict of interest. By this is meant both the case where a collaborator pursues an interest other than the business mission and the balancing of stakeholder interests or takes "personal" advantage of business opportunities of the company, and the case where representatives of customers or suppliers, or public institutions, act contrary to the fiduciary duties associated with their position.
Natlive ensures the confidentiality of the information in its possession and refrains from seeking confidential data, except where expressly permitted and in accordance with applicable regulations. In addition, Natlive's collaborators and employees are required not to use confidential information for purposes other than those related to their own business.
2e) Value of human resources.
Natlive employees are an indispensable element of the Company's success. For this reason, Natlive protects and promotes the value of human resources in order to improve and increase the wealth and competitiveness of the skills that characterize each employee.
2f) Fairness of authority.
In the signing and management of contractual relationships involving the establishment of hierarchical relations - especially with collaborators - Natlive is committed to ensuring that authority is exercised fairly, avoiding any abuse of it. In particular, Natlive ensures that authority does not turn into an exercise of power detrimental to the dignity and autonomy of the collaborator, and that choices of work organization safeguard the value of collaborators.
2g) Respect for the person.
Natlive guarantees the physical and moral integrity of its employees, safe, healthy and dignified working conditions and environments. Requests or threats aimed at inducing people to act against the law or the code of ethics, or to engage in behavior detrimental to each person's moral and personal beliefs and preferences are not permitted under any circumstances.
2h) Transparency and completeness of information.
Natlive's employees and collaborators are required to give complete, transparent, clear and detailed information, so that, when setting up relations with the company, stakeholders are able to make autonomous decisions aware of the interests involved, the alternatives and the resulting consequences.
2i) Diligence and accuracy in the execution of tasks and contracts.
Contracts and work assignments must be performed as consciously agreed upon by the parties. Natlive undertakes not to exploit conditions of ignorance or incapacity of its counterparts.
2l) Fairness and equity in contractual matters.
It is to be avoided that in existing relationships, anyone acting in the name and on behalf of Natlive tries to take advantage of contractual gaps, or unforeseen events, to renegotiate the contract for the sole purpose of exploiting the position of dependence or weakness in which the counterparty has found itself.
2m) Quality of services and products.
Natlive bases its activities on the satisfaction and protection of its customers, taking into account requests that can foster an improvement in the quality of products and services. For this reason, Natlive orients its research, development and marketing activities to high quality standards of its services and products.
2n) Fair Competition.
Natlive intends to protect and enhance fair competition by refraining from any form of collusive behavior.
2o) Responsibility to society.
Natlive is aware of the social role of the Company and the influence, even indirectly, that its activities can have on the conditions, economic and social development and general welfare of the community. For this reason, Natlive intends to conduct its investments and make its industrial choices in an environmentally sustainable manner, respecting local and national communities.
2q) Environmental Protection.
The environment is a primary asset that Natlive is committed to safeguarding; to this end, it plans its activities by balancing economic initiatives and unavoidable environmental needs, in consideration of the rights of new generations to a better future. Natlive is therefore committed to improving the environmental and landscape impact of its activities, as well as preventing risks to people and the environment not only in compliance with current regulations, but taking into account the development of scientific research and the state of the art.
Art. 3 Customers
Natlive is committed to not arbitrarily discriminating against its clients, always adopting guidelines marked by impartiality.
3b) Contracts and communications to clients.
Natlive's contracts and customer communications (including advertisements) must be:
- Clear and simple, formulated in language as close as possible to that normally used by interlocutors;
- Compliant with current regulations, without resorting to elusive or otherwise unfair practices (such as, for example, the inclusion of practices or clauses that are vexatious to consumers) and pledging not to use misleading or untruthful advertising tools.
- Comprehensive, so as not to overlook any element relevant to the customer's decision.
3c) Behavior style.
Natlive's style of behavior toward customers is based on helpfulness, respect and courtesy, with a view to a collaborative and highly professional relationship. In addition, Natlive is committed to limiting the obligations required of its customers and to adopting simplified, secure and, as far as possible, computerized and inexpensive payment procedures.
3d) Anti-competitive practices.
In the negotiation stages with customers, employees and collaborators should be careful in order to avoid potential violation of antitrust and unfair competition regulations.
The Company is free to choose - on the basis of its own independent assessment - the customers with whom to finalize business agreements. However, this right may find limits in cases where the Company has entered into obligations through agreements previously concluded with third parties. Even the slightest doubt as to the existence of one of these constraints, should prompt consultation with the relevant Sales Department, even before engaging in any discussion with the customer concerning actual or potential competitors.
3e) Relations with the Public Administration.
Natlive - as a supplier of services and products provided or sold to the Public Administration, central and/or local - may incur particular forms of responsibility.
In commercial negotiations with the Public Administration or in participating in public tenders, the Company must be particularly attentive to the confidentiality, integrity, truthfulness and completeness of the required documentation and compliance with the general and/or specific regulations that oversee the entire contracting process.
Natlive intends to dialogue at all times in a transparent and fair manner with all public clients, as well as with consulting structures that are of technical support to Natlive in offering to the Public Administration. During proposals and negotiations with the Public Administration, the Company must always be fair, transparent and diligent in all stages of the negotiation.
In addition, depending on the specific legal system in which the company operates, Natlive's employees and collaborators are required to comply with applicable laws and rules.
Art. 4 Employees and Personnel Policies
4a) Human Resources.
Human resources are an indispensable and fundamental element of the company's existence. The dedication and professionalism of employees are crucial values and conditions for achieving Natlive's goals. Natlive is committed to developing the skills and competencies of each employee so that the energy and creativity of individuals finds full expression for the realization of their potential.
Natlive provides all employees with equal employment opportunities, making sure that everyone can enjoy equal opportunities on the basis of merit and without any discrimination. In the performance of smart working, the worker is required to comply with confidentiality obligations, pursuant to Presidential Decree No. 62 of April 16, 2013, the Code of Conduct and the Code of Ethics.
Failure to comply with the provisions of these Regulations constitutes conduct relevant for disciplinary purposes and may consequently result in the application of the prescribed disciplinary sanctions.
Natlive interprets its entrepreneurial role both in the protection of working conditions and in the protection of the psycho-physical integrity of the worker, respecting his or her moral personality, avoiding that this be subjected to illicit conditioning or undue hardship.
Natlive expects employees, at every level, to cooperate in maintaining a climate of mutual respect for each other's dignity, honor and reputation in the company. Personnel Management will intervene to prevent insulting or defamatory interpersonal attitudes. Every human resource of Natlive is expected to carry out their activities responsibly, honestly, diligently and with good judgment, in accordance with the company policies, procedures and general guidelines established by Natlive. The Company intends to adhere to the highest ethical standards in the conduct of its business activities.
It is therefore incumbent upon each individual to avoid situations of conflict of interest or other situations that may be potentially harmful to Natlive. Therefore, even the appearance of a lack of integrity should be avoided.
4b) Mutual Respect.
It is Natlive's policy to foster an internal climate in which each employee interacts toward other colleagues, honestly, with dignity and mutual respect, in a work environment in which human resources communicate openly, which facilitates the achievement of the Company's goals and objectives, and which promotes individual creativity and growth.
4c) Conflict of Interest.
In order to maintain the highest level of integrity in the conduct of company business, each employee is expected to avoid any activity or situation of personal interest that constitutes or may constitute an obstacle between individual interests and those of Natlive. Employees must consider the company's interests a top priority and must avoid any action that could result in disadvantage or harm to Natlive. By way of example only: employees must refrain from taking advantage of their position in order to favor business or persons outside the Company or to favor themselves, to the detriment of Natlive. In addition, no employee, directly or indirectly, may participate in management or hold a significant stake or work in business ventures that are toward Natlive in competitive and/or supply or customer relationships, unless such participation or connection has been disclosed to Natlive in advance, and approved in writing by management.
Similarly, an employee may not participate directly or indirectly in any business activity involving contact or work with Natlive customers unless such participation or connection has been communicated to Natlive in advance and approved in writing by management.
4d) Gifts, bribes and favors.
In institutional dealings with public officials or members of the Public Administration, an offence could be committed even where the utility delivered or transferred for the benefit of the public official is not made with the volitional intent to influence a choice in violation of rules or laws.
Consequently, it is specifically prohibited to:
- Promising or making cash disbursements to persons belonging to the Public Administration, Italian or foreign, for purposes other than institutional and service purposes.
- Distributing gifts and gratuities in excess of normal business practices or courtesy, or otherwise aimed at acquiring favorable treatment in the conduct of any business activity. Allowed gifts may only be of small value or aimed at promoting charitable or cultural initiatives, or the Natlive Brand and products and services.
Employees are responsible for full compliance with all applicable anti-corruption legislation in the country in which they are located.
The payment of bribes or other forms of unlawful benefits to public officials are prohibited actions, unacceptable and will not be tolerated by Natlive.
4e) Use of company resources and assets.
The company's tangible and intangible assets, including all forms of intellectual and industrial property, are a fundamental asset of Natlive, and therefore each employee is obliged to diligent use, careful control, and proper custody, against any loss or misuse of the assets entrusted to him or her. Company assets, especially equipment, telephones, internal information systems (e.g., INTERNET, and e-mail), databases, inventions, innovative processes, trade secrets, and other confidential information are to be used exclusively for purposes related to the performance of the specific work activity. Employees must not carry out activities on their own behalf or on behalf of third parties during working hours and - for the exercise of such activities - are therefore neither entitled nor authorized to use the company's equipment, except for specific exceptions and express limitations.
The use of computer work tools by employees must therefore comply with company policies and applicable laws. Employees must not use these tools in a manner that harms or offends third parties.
All information processed or transmitted electronically is to be considered company property and may only be transmitted for work-related purposes.
4f) Information about Natlive.
The disclosure of information about Natlive to third parties is prohibited, unless such information has been made public or the disclosure of such information is within the scope of duties. It is also prohibited to discuss confidential business of the Company in public or otherwise in places open to the public and where outsiders may be present.
4g) Intellectual and Industrial Property.
It is Natlive's policy to respect the intellectual or industrial property assets of third parties. Likewise, the Company intends to protect its tangible and intangible assets (such as software, intellectual works, databases, industrial finds) protected by copyright or private rights. Employees are prohibited from duplicating, marketing or distributing works protected by copyright or privative rights without specific authorization from Management.
Trademarks and distinctive signs, including company logos, must always be used in accordance with their normal purpose, in accordance with company guidelines. Questions regarding the proper use of trademarks should be reported to Natlive Management.
4i) Contacts with External Organizations.
Management must be informed immediately about any question or contact from external auditors, investigators or public inspectors. Employees who are requested by Natlive, through any of its Management, to participate in internal inquiries or investigations must ensure full cooperation. Under no circumstances will conduct by employees aimed at improperly influencing, or obstructing or impeding the performance of the activities of auditors or investigators be deemed permissible.
4l) Equal Opportunity/Discrimination/Harassment Prohibition.
It is Natlive's policy to ensure equal access and professional development opportunities for all as well as to take positive actions aimed at having a workforce that is representative of diverse social backgrounds. This means that any decision pertaining to the evaluation of Human Resources will be made in a non-discriminatory manner. Natlive does not consider admissible nor will it tolerate forms of discrimination based on race, color, sex, age, religion, physical condition, marital status, sexual orientation, citizenship, ethnic origin, political opinion or any other discrimination contrary to law. Natlive does not condone sexual harassment, meaning:
- situations in which determinations, initiatives and company decisions relevant in any way to the recipient's working life are conditioned on the acceptance of sexual favors;
- proposals of private interpersonal relationships, conducted despite an expressed or reasonably evident dislike, which may, in relation to the specificity of the situation, disturb the recipient's serenity with objective implications on his or her work expression.
Natlive will not put in place or tolerate any form of retaliation against employees who have complained of discriminatory or harassing ways, nor against employees who have provided news about it.
4m) Alcohol or drug abuse.
Natlive requires that each employee personally contribute to maintaining a work environment that respects the sensibilities of others. This requirement is considered unfulfilled when, in the course of employment and in the workplace:
- one serves under the effects of abuse of alcohol, drugs or substances of similar effect;
- one consumes or disposes of drugs in any capacity in the course of work performance.
Chronic states of dependence on substances of this nature, when they appreciably affect the work environment, will be - for contractual repercussions - equated with the previous cases.
4n) Laws against Boycott and Embargo/Exports.
It is company policy to conduct business activities in accordance with all laws and regulations on boycotts and embargoes. Legislation against Boycott is aimed at the purpose of avoiding corporate involvement in the affairs of boycott policies of one country against another.
It is the policy of the Company to comply with all laws and regulations regarding the export, re-export and import of materials and specific technical knowledge.
Article 5 Rules of conduct in dealing with the community
5a) Environmental Policy.
Natlive's environmental policy also finds support in the knowledge that the environment can be a competitive advantage in an increasingly large and demanding market in the area of quality and behavior.
Natlive's strategy is geared toward investments and activities that respond to the principles of sustainable development; in particular:
- within national and international programs, promote actions and behaviors that consider the environment variable as strategic.
Natlive promotes the following environmental policy tools:
- environmental awareness and training activities for customers and employees, which aim to disseminate initiatives externally and internally and to increase the skills and professionalism of practitioners;
- programs for rational energy use aimed at customers;
- realization of products capable of pursuing high energy savings.
5b) Relations with Professional Associations.
Natlive believes that dialogue with associations is of strategic importance for the proper development of its business; therefore, it establishes a stable channel of communication with the associations representing its stakeholders, in order to cooperate in respect of mutual interests, present the company's positions and prevent any conflict situations.
- ensures response to the comments of all associations;
- whenever possible, is oriented to inform and involve, on issues affecting specific classes of stakeholders, the most qualified and representative trade associations.
5c) Economic relations with parties, trade unions and associations.
Natlive does not finance parties both in Italy and abroad, their representatives or candidates, nor does it make sponsorships of congresses or parties whose purpose is exclusive political propaganda. It refrains from any direct or indirect pressure to political figures (e.g., through granting Natlive facilities, accepting referrals for hiring, consulting contracts).
Natlive does not make contributions to organizations with which a conflict of interest may arise (e.g., trade unions, environmental or consumer protection associations); however, it is possible to cooperate, including financially, with such organizations for specific projects based on the following criteria:
- purpose traceable to Natlive's mission;
- clear and documentable allocation of resources;
- express authorization from the functions in charge of managing such relationships within Natlive.
5d) Contributions and sponsorships.
Natlive may accede to requests for contributions limited to proposals coming from entities and associations that are declared non-profit and have regular statutes and articles of incorporation, that are of high cultural or charitable value and that have a national scope or, in any case, that involve a considerable number of citizens. Sponsorship activities, in the social, environmental, sports, entertainment, and art themes, are intended only for events that offer a guarantee of quality or for which Natlive can collaborate in the planning, so as to ensure their originality and effectiveness.
In any case, when choosing the proposals to which to adhere, Natlive pays special attention towards any possible conflict of interest of a personal or corporate nature (e.g., kinship relationships with the individuals concerned and links with bodies whose activities may in some way favor the company's activities).
5e) Institutional Relations.
Any relationship with state or international institutions, is due exclusively to forms of communication aimed at assessing the implications of legislative and administrative activity with respect to Natlive, responding to formal and/or informal requests, or otherwise making known the position on issues relevant to society. To this end, Natlive is committed to:
- establish without discrimination, stable channels of communication with all institutional interlocutors at the international, community and territorial levels;
- represent the interests and positions of the Company in a transparent, rigorous and consistent manner, avoiding attitudes of a collusive nature.
In order to ensure maximum clarity in relations, contacts with institutional interlocutors take place exclusively through contact persons who have received explicit mandate from the competent top management figures of Natlive.
Art. 6 Suppliers
6a) General Policy.
It is Natlive's policy to negotiate in good faith and in a transparent manner with all potential suppliers as well as to avoid engaging in unjustifiably biased negotiations. In the context of this Code, the term "Suppliers" encompasses all entities from which Natlive receives materials or services, including licensors, contractors and subcontractors.
Natlive places the satisfaction of its customers as its primary objective, and consequently quality forms of collaboration will be developed with those suppliers who, better than others, will be able to ensure that the needs of Natlive's customers and users of its products and services are met.
6b) Supplies, Contracts and Subcontracts.
Supplies, tenders and subcontracts ("Supplies") must be justified by actual business needs and the choice of Supplier must, in any case, be made taking into account exclusively objective, technical and economic parameters.
The selection of Suppliers must be aimed exclusively at entities capable of providing precise guarantees of reliability and technical suitability for the performance of the services requested from time to time.
It will be the care and responsibility of the competent offices of Natlive in charge of the selection, management and control phases of Suppliers, to request and keep updated over time, and to ascertain all the elements useful for the purpose of qualifying the Supplier in terms of its technical and professional suitability, and this also pursuant to and for the purposes of the provisions of the regulations in force regarding the protection of health and integrity in the workplace, requesting information such as, by way of example, the company organization, the personnel used, previous experience with other companies in the sector, budget data.
In particular, in the case of Suppliers who already operate and collaborate with Natlive it will be necessary to periodically verify that these Suppliers have continued to offer the contractual services on a regular basis, and that no changes have occurred in the company's organization such as to compromise an exact fulfillment of the required services.
The performance of the services by the Supplier must be marked by absolute transparency and, at all times, Natlive will have the right and title to proceed to an audit aimed at verifying the actual performance of the services and the fulfillment of all contractual obligations.
The amount of the Supply must always be commensurate with the actual value of the services deducted in the Supply contract. In the selection of the Supplier and in the stipulation of the Supply contract, all legal regulations and rules regarding subcontracting must be respected, especially in the area of public contracts. Natlive will consider the advisability, for supply contracts of particular importance the possibility of formalizing, under penalty of termination of the contract and compensation for all damages caused, a commitment on the part of the Supplier to comply with all the principles of this Code and to comply with applicable regulations.
6c) Consultants, Agents and External Collaborators ("consultants").
The use of the professional activity of external consultants, agents or professionals must be justified, by the proposing party, with an indication in writing of the relevant specific reasons underlying the proposal. If the work of Consultants is used, the nature of the services to be requested from them must be identified in advance. The selection of the Consultant must strictly be in favor of persons who, by their proven seriousness and professional preparation, are best able to fulfill the services requested.
The reasons for the selection of the Consultant must be stated in writing with an adequate level of analyticity and understanding, and must refer, for example, to any previous positive relations between the Consultant and Natlive, to the experience of such Consultant in the field in which the activity is required, to the manner in which the Consultant intends to carry out its activity, either individually or through studio associates or through other forms of organization.
The performance of the service by the Consultant must always take place with the utmost transparency: Natlive must be put in a position to verify, at any time, what services have actually been performed and whether the Consultant is fulfilling its contractual obligations.
The Consultant, in turn, must periodically inform the Company of the activities it is performing.
Payment for services to the Consultant must be made on the basis of a detailed statement of the activities performed by the Consultant, so that it is possible to verify the actuality and value of the services performed. Remuneration to the Consultant shall be commensurate with that normally charged for similar services.
The act of appointment to the Consultant must formalize the latter's commitment, under penalty of termination of the relationship and compensation for all damages caused, to comply with the principles of this Code and all legal regulations.
Any form of recommendation or pressure on the bodies of the companies responsible for choosing Consultants or aimed at guiding the decision of the latter in a way that is not in accordance with the company's interests is prohibited: any behavior contrary to the laws of the countries in which the Company operates must be considered contrary to the company's interests.
6d) Prohibition of Bribes.
It is Natlive's policy to ensure that the decision-making phases regarding the awarding of supplies, contracts or subcontracts are phases and moments characterized by objectivity of judgment and absolute compliance with regulations. Employees, Suppliers and Consultants (in the previous meaning) are prohibited from offering or accepting bribes. A "bribe" is defined as any amount, utility, commission, advantage, gift, value or compensation of any kind offered, directly or indirectly, for the purpose of influencing business decisions, obtaining the award of contracts, or other favorable treatment.
Art. 7 Competitors
7a) Unfair Competition.
Natlive prohibits the adoption of unfair methods of competition.
7b) Relationships with competitors.
Any communication with competitors involves opportunities for risk. As a general rule, Natlive suggests involving management in advance, for the consideration of proposals importing forms of cooperation with a competitor.
In contacts with competing companies, Natlive personnel should avoid dealing with topics such as prices or other Natlive offer terms and conditions (except for services or goods that the competitor is buying from Natlive or offering to Natlive), costs, inventories, production plans, market research, or other proprietary or confidential information whose communication is not strictly necessary and relevant to the specific negotiation negotiation.
In situations where Natlive is considering working as a team with another company to respond to a particular offer, that company will not be considered a competitor with respect to that specific situation. However, the same company or organization with which
Natlive is working as a team on a specific project, could compete with Natlive on other projects and therefore, only in those situations, be considered a competitor. Agreements with competitors could violate Antitrust Law and therefore, prior to entering into such agreements, it is necessary to consult with management in advance for appropriate legal review.
Employees are prohibited from reaching agreements or understandings with competing companies to influence prices or other conditions of sale.
7e) Compliance with local laws.
Laws relating to the protection of competition may differ from country to country, at times, even conflicting with each other. It is Natlive's policy to ensure that its business conduct consistently complies with the law of the host country, while continuing to observe the guidelines set forth in this Code.
Article 8 Violations
Employees and contractors must promptly report to their superiors any circumstances that involve, or appear to involve, a deviation from the standards of Ethics and Business Conduct. If, for justifiable reason or expediency, a direct reference to one's superior is deemed inadvisable, it will be the employee's care and duty to communicate directly to the CEO or the CDA. Omitting or failing to report such circumstances constitutes a violation of this Code.
Reports will be treated with the utmost confidentiality, and all reported violations (except anonymous ones) will be immediately investigated. It is mandatory that persons who have reported alleged violations refrain from independently conducting preliminary investigations. Indeed, the investigative stages regarding such violations may involve complex legal issues, and by taking autonomous and unauthorized steps, the integrity and validity of institutional actions could be compromised.
Employees and collaborators are required to cooperate unreservedly in the investigative stages and to provide all information in their possession regarding such violations, regardless of whether the violations are considered relevant. Failure to cooperate, or only partial cooperation with investigative activities may lead to severe disciplinary measures, including dismissal.
An employee or collaborator involved in a violation of the standards of Ethics and Business Conduct of this Code is subject to disciplinary action in accordance with the laws and regulations provided in the applicable legal system. According to the provisions of the laws and regulations referred to above, as well as according to the applicable Collective Bargaining Agreements, sanctions could include reprimand, fine, suspension or dismissal.
Natlive reserves the right to amend the Standards of Ethics and Business Conduct set forth in this Code at any time and without notice, by simple notice.
Every employee is expected to cooperate and comply fully with the spirit and letter of the standards specified in this Code. The publication of this Code lends strength and credibility to Natlive's intention to conduct business ventures in a moral, legal and ethical manner. The Company believes that compliance with these Norms is an essential and indispensable element in the achievement of its goals and future success.