CODE OF ETHICS and CONDUCT
This Code of Conduct defines the minimum standards of conduct and business practices that KeyCrime expects to be adhered to. Compliance with this Code of Conduct is expected even if the laws and regulations in force are more permissive than this Code of Conduct. If the laws and regulations in force are more restrictive, it is always mandatory to comply with these legal requirements.
Key Crime 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 this Code of Ethics, in the belief that reliability is built on a daily basis by respecting the rules and valuing people.
This Code of Ethics therefore represents a distinctive and identifying element towards the market and third parties, the knowledge and sharing of which is required of all those who work in the Company or who collaborate with it. It constitutes the foundation of our business and the first step in contributing to the pursuit of our vision.
KeyCrime’s objective is therefore 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, in order to ensure added value for the Employee, for the Customer and, in general, for the Community.
Our Code is not just a document, it is what we believe in, it is how we live and how we excel. This is how we improve our business performance and build KeyCrime’s reputation in the market. It’s how we place ourselves on our customers and our resources first. It’s our way of turning integrity into action – each of us, anytime, every day.
The Code will be widely disseminated within the internal governance structure, and broadly communicated externally including via the company website.
KeyCrime also undertakes to adopt all further provisions so that the principles and provisions of the Code can be promptly disclosed and applied.
KeyCrime reserves the right to change this Code of Conduct at any time by posting an amended version of the Code of Conduct on the KEYCRIME website on the appropriate page or through notifications.
KeyCrime’s mission is to support the Police Forces around the world in their activities aimed at combating widespread crime. To achieve this ambitious goal, the company has developed an innovative solution in the criminal analysis sector, the use of which is intended specifically and exclusively for the Police Forces and Judicial Authorities, with the aim of supporting these Institutions in all phases of the process of crime analysis, from the guided and structured collection of information through to the processing of that data.
The present Code of Ethics and Conduct (hereinafter the “Code”) is a set of values, morals and ethics: behavioral guidelines which should govern KeyCrime (the ‘Company’) board members, the Board, employees and collaborators, suppliers, partners, and in general, all third parties who come into contact with the company in their work and all those who directly or indirectly, permanently or temporarily establish relationships or operate on behalf of the Company (of hereinafter, the “Recipients”).
The Code illustrates the set of ethical and moral principles underlying the Company’s business as well as the lines of conduct adopted by the same both within its business (in relations between employees) and externally (in relations with institutions, suppliers, customers, business partners, political and trade union organizations as well as the media (hereinafter, the “Third Parties”).
Compliance with these principles is of fundamental importance to achieve the Company’s corporate mission and to guarantee its reputation in the socio-economic context in which it operates.
Preliminarily, it should be noted that KeyCrime firmly believes that every activity must be carried out ethically, recognizing itself in the principle enshrined in art. 41 of the Italian Constitution, according to which private economic initiative “cannot be carried out in contrast with social utility or in such a way as to damage security, freedom, human dignity.”
This Code is binding for the directors and employees of the Company, as well as for all those who work and collaborate, on a permanent or fixed-term basis, on behalf of the Company (hereinafter, the “Recipients”).
If you become aware of any situation that involves illegal or immoral aspects and that involves or is related to the sale of products or services that the Company provides, it is mandatory to send a specific report immediately to firstname.lastname@example.org and communicate all the information you have about the incident or situation. The information provided to KeyCrime must be accurate to the best of its knowledge and the Company expects assistance in any investigation into the reported incident or situation. Reporting false information to KeyCrime may lead to the termination of business relations with the Company and all related contracts.
The conduct of the Recipients, at all company levels, must be based on the principles of legality, correctness, non-discrimination, confidentiality, diligence, and loyalty.
KeyCrime operates in full compliance with the law and this Code.
All Recipients are therefore required to observe all applicable legislation and to constantly update themselves on legislative changes, also making use of the training opportunities offered by KeyCrime. The Company considers the transparency of financial statements and accounting a fundamental principle for the exercise of its business and for the protection of its reputation.
Correctness and moral integrity are a duty for all Recipients.
Recipients are required not to establish any privileged relationship with third parties, which is the result of external solicitations aimed at obtaining improper advantages.
In carrying out their activities, the Recipients are required not to accept donations, favors or benefits of any kind (except for objects of modest value authorized by the Company) and, in general, not to accept any counterpart in order to improperly grant benefits to third parties.
In turn, the Recipients must not make donations of money or goods to third parties or in any case offer illicit benefits or favors of any kind (except for objects of modest value or commercial courtesy gifts authorized by the Company) in connection with the activity they carry out for the benefit of KeyCrime.
The intrinsic conviction of acting in the interest of the Company does not exempt the Recipients from the obligation to promptly observe the rules and principles of this Code.
In the selection and management of personnel, in the organization, in the choice, selection and management of suppliers, as well as in relations with Bodies and Institutions, KeyCrime avoids and condemns any discrimination concerning age, sex, race, guidelines sexual relations, the state of health, political and trade union opinions, religion, culture and nationality of its interlocutors.
At the same time, KeyCrime favors integration, promoting intercultural dialogue, the protection of the rights of minorities and vulnerable individuals.
Confidentiality and Protection of Intellectual Property
KeyCrime undertakes to ensure the protection and confidentiality of the Recipients’ personal data, in compliance with all applicable legislation on the protection of personal data and the Protection of Intellectual Property.
Recipients are required not to use confidential information, learned as a result of their work, for purposes unrelated to the exercise of this activity, and in any case to always act in compliance with the confidentiality obligations assumed by KeyCrime towards all Third Parties.
In particular, the Recipients are responsible for protecting the intellectual property rights of KeyCrime, the customer, and Third Parties. You must not reproduce any copyrighted software, documentation or other materials unless you are duly authorized to do so. The data privacy requirements in force must be observed.
The relationship between KeyCrime and its employees is based on mutual trust: employees are therefore required to work to promote the interests of the company, in compliance with the values set out in this Code.
Recipients must refrain from any activity that could constitute a conflict with the interests of KeyCrime, renouncing the pursuit of personal interests in conflict with the legitimate interests of the Company.
In cases where the possibility of a conflict of interest can be represented, the Recipients are required to contact their hierarchical superior without delay so that the company can 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.
KeyCrime and the Recipients undertake to engage in fair competition, in compliance with national and EU legislation, in the awareness that virtuous competition constitutes a healthy incentive for innovation and development processes, and also protects the interests of consumers and the community.
Selection of personnel
The assessment and selection of personnel are carried out according to fairness and transparency, respecting equal opportunities in order to combine the needs of KeyCrime with the professional profiles, ambitions and expectations of the candidates.
KeyCrime undertakes to adopt any useful measure to avoid any form of favoritism in the personnel selection process using objective and merit-based criteria, respecting the dignity of the candidates as well as in the interest of the good performance of the company.
The personnel hired, also through the implementation of this Code, will receive clear and correct information about the roles, responsibilities, rights and duties of the parties.
Management of personnel
KeyCrime protects and enhances its human resources, committing itself to maintaining constant the conditions necessary for the professional growth, knowledge and skills of each person, carrying out the appropriate training for professional growth and any initiative aimed at pursuing this aim.
KeyCrime promotes the participation of workers in the life of the company, providing participatory tools to collect opinions and suggestions of workers, ensuring their widest participation.
No worker can be obliged to perform tasks, services or favors not required based on their employment contract and their role within the company.
The Company is firmly committed to combating episodes of mobbing, stalking, psychological violence and any behavior that is discriminatory or harmful to the dignity of the person inside and outside the company premises.
Relations between employees must be carried out with loyalty, correctness and mutual respect, in compliance with the values of civil coexistence and people’s freedom.
KeyCrime is committed to offering its staff a healthy, safe and respectful working environment for the dignity of workers.
Safety in the workplace is ensured both by rigorously implementing the provisions required by the law, and by actively promoting the culture of safety through specific training programs. Staff training is a central element of the management system adopted by the Company.
KeyCrime protects the health of its workers, also ensuring compliance with hygiene and health prevention regulations.
Compliance with internal procedures
KeyCrime believes that management efficiency and a culture of control are indispensable elements for achieving its objectives.
Recipients are required to strictly observe the procedures and instructions within the company.
Recipients must act on the basis of their respective authorization profiles and must keep all suitable documentation to keep track of the actions taken on behalf of the company.
Management of accounting and finances
In the accounting management activity, the Recipients are called to act in compliance with the principles of truthfulness, accuracy and transparency, so that the reputation of KeyCrime is protected both internally and externally.
Compliance with these principles also allows the company to plan its operating strategies based on its real economic and equity situation.
All the 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 equity or economic elements based on valuations and estimates, the relative reporting must be based on criteria of reasonableness and prudence.
Protection of Company Assets
The Recipients exercise their functions trying to rationalize and contain the use of company resources.
Recipients are required to correctly apply the provisions relating to security to protect hardware devices from unauthorized access, which could seriously damage the personal data protection rights of KeyCrime staff and customers.
KeyCrime makes available to Third Parties suitable communication tools through which they can interact with the company to forward requests, ask for clarifications or make complaints.
KeyCrime promotes effective corporate communication capable of putting the company in contact with society as a whole, in order to acknowledge the demands, needs and needs of the community and to spread its values and mission.
The information disclosed to Third Parties is complete and accurate so that recipients are allowed to make correct and informed decisions.
KeyCrime’s advertising promotion respects ethical values, protecting minors and repudiating vulgar or offensive messages.
Relationships with the Authorities and Public Administration
Relations with the Authorities and with the Public Administration must be based on the utmost clarity, transparency and collaboration, in full compliance with the law and according to the highest moral and professional standards.
The Recipients, unless expressly authorized, cannot communicate in the name of and on behalf of KeyCrime with the Authorities and with the Public Administration.
In relations with Public Officials, with Public Service Officers, and with the Public Administration in general, the authorized Recipients shall comply with the highest levels of correctness and integrity, refraining from any form of pressure, explicit or veiled, aimed at obtaining any undue advantage for himself or for KeyCrime.
In this regard, the authorized Recipients will be required to strictly observe the provisions of this Code, as well as, more generally, the provisions of the directives issued by the management of KeyCrime. It is mandatory to know and comply with all laws, rules, regulations, including procurement rules and contractual clauses that regulate the purchase of goods and services by government entities to which they are marketed or advertised, directly or indirectly, products and / or services provided by KeyCrime, including federal, state, local and other state-owned entities, as well as state-owned entities, which are state-controlled or subject to government procurement rules (“Government Clients”). Keep in mind that activities that may be considered appropriate when dealing with non-governmental customers may be inappropriate or even illegal when dealing with governmental customers.
Relationships with Political Organizations and Unions
KeyCrime does not favor or discriminate against any political or trade union organization.
The Company refrains from making any undue contribution in any form to parties, trade unions or other social formations, except for specific exceptions and in any case always within the limits of what is allowed by the regulations in force.
Recipients are required to refrain from any direct or indirect pressure on politicians or trade union representatives.
Relationships with clients and suppliers
The Recipients deal with third parties with courtesy, competence and professionalism, in the belief that their conduct depends on the protection of the image and reputation of the company and consequently the achievement of corporate objectives.
In particular, the Recipients must refrain from any form of unfair or deceptive behavior that could induce customers or suppliers to rely on unfounded facts or circumstances.
Recipients are required to make a constant effort to offer punctual and high quality services to customers, trying to limit any form of disservice or delay in order to maximize customer satisfaction.
Relations with suppliers are based on loyalty, correctness and transparency.
The choice of suppliers is made on the basis of objective criteria of cost-effectiveness, opportunity and efficiency.
The choice of suppliers on a purely subjective and personal basis or, in any case, by virtue of interests contrasting with those of the company is not allowed.
The Recipients must put in place every possible control so that suppliers and customers are able to comply with the fundamental ethical principles set out in this Code
Compliance with the provisions of this Code is entrusted to the prudent, reasonable and careful supervision of each of the Recipients, within the context of their respective roles and functions within the company.
All Recipients are invited to report to their direct superiors the facts and circumstances potentially in conflict with the principles and provisions of this Code.
The management of KeyCrime and the bodies responsible for this purpose take all necessary measures to put an end to the violations, being able to resort to any disciplinary measure in compliance with the law and workers’ rights.
The internal control system is oriented towards the adoption of tools and methodologies aimed at contrasting potential business risks, in order to ensure compliance not only with the laws, but also with internal provisions and procedures.
The violation of the principles established in the Code and in 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, commercial and financial partners.
Such violations will therefore be immediately prosecuted by KeyCrime in an incisive and timely manner, through the adoption of adequate and proportionate disciplinary measures.
The effects of violations of the Code of Ethics and internal protocols must be taken into consideration by all those who, for whatever reason, have relations with KeyCrime. Depending on the seriousness of the conduct by the person involved in one of the illegal activities envisaged by the Code, KeyCrime will immediately take the appropriate measures, regardless of any prosecution by the judicial authority.
Without prejudice to the foregoing, behaviors in violation of the Code of Ethics include:
- serious non-fulfillment for employees (white-collar workers, middle managers and managers), with the penalties, applied according to the severity, provided for by the national collective bargaining agreement for the category; in the case of pending criminal action or execution of a measure restricting personal freedom taken against the employee, before adopting the disciplinary measure, the sanction of suspension from service and from remuneration may be adopted, for the duration corresponding to the outcome of the criminal action or until the end of the duration of the provision restricting personal freedom;
- just cause for revocation of the mandate of the directors;
- cause of immediate termination of the relationship, in the most serious cases, for external and para-subordinate collaborators;
- cause of 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 adequacy with respect to the alleged violation.
In all the aforementioned cases, KeyCrime also reserves the right to exercise all the actions it deems appropriate to compensate for the damage suffered as a result of conduct in violation of the Code of Ethics.