Security in Italy

Art. 1 – Purpose and scope of application
The following code of ethics, hereinafter referred to as “code”, contains the guiding principles of the behaviour of entities working at OSINT Centre ltd, such as employees and external consultants with a VAT registration number. This is for the protection of personal data and specifies the values of loyalty, impartiality, diligence and industriousness, provided for under the current laws and regulations, particularly the TULPS (Consolidated Text of Laws on Public Security). The activity of these entities must comply with the existing laws and regulations, namely, TULPS, Civil and Criminal Code, and the respective Procedure Codes. This guarantees the entrusted tasks, the impartiality and transparency of administrative and operational activities, and compliance regarding confidentiality obligations. The code applies to all employees and external consultants with a VAT number, even when there are no placements for temporary staff , control staff , part-time staff and the secondment of staff. The code also applies to consultants and persons authorised to attend the Office to carry out studies or research. The external consultants in the VAT system operating with OSINT Centre ltd are also obliged to comply with this code.

Art. 2 – General provisions
The employee and external consultant aim to respect the code at the time of the assignment and to maintain a conduct based on the principles of loyalty, impartiality, integrity and honesty. The employee avoids any act or behaviour that violates or is believed to violate the provisions of the law, the regulation or the code content. Relationships between the Office and external employees and consultants are based on trust and collaboration. The employee makes sure that relationships with colleagues are friendly and avoid actions or behaviour that might be classed as hostile or likely to cause conflict. The employee tailors his work and assets to conform to the values of correctness, economy, efficiency and effectiveness. The employee dedicates the right amount of time and effort to office work, avoiding absence or improper leave. The employee and consultant must limit the use of telephone equipment, photocopiers and processors unless absolutely necessary (for personal reasons), even when they are contacted. For external relationships, the employee and consultant behave in such a way as to determine trust and collaboration on the part of the entities who come into the office. They are polite and offer their services to the public, dealing with any issues quickly and efficiently.

Art. 3 – Impartiality
The employee and consultant (also with VAT) shall operate with impartiality, avoid preferential treatment and unequal treatment, refrain from undue coercion rejecting it, adopt initiatives and decisions with the utmost transparency and avoid creating or taking advantage of situations of privilege. In relations with the stakeholders and for any activity whatsoever with Osint Centre, the employee and consultant shall not enter into commitments or make personal promises that could influence the fulfilment of official duties. Notwithstanding the rights of the association and their right to join political parties and trade unions, the employee and consultant inform the Operations Office Manager of their membership of associations, clubs or any other type of entity whose interests may influence the performance of office functions.

Art. 4 – Integrity
The employee and consultant shall not use the office for private and personal purposes or benefits. The employee and consultant shall not take advantage of the position he holds in the office to obtain benefits or advantages from external or even confidential relations. In private relations, the employee and consultant must avoid declaring or implying his stance unless the objective requires it. The employee and consultant shall not use information that is unavailable to the public, that is not made known to the public, or that is obtained confidentially through office activities, to make profits or for private interests. The employee avoids receiving benefits of any kind, even during trips, seminars and conferences, which may or appear to influence their own of judgement and impartiality. Moreover, they shall not solicit or accept any gift or benefit for themselves or others, from entities who are interested in the activity of Osint Centre ltd. to those who intend to enter into relations with it, with the exception of gifts of modest value. In the event that he or she is put under unlawful pressure, or is offered gifts, benefits or anything else of high value, the employee must promptly notify the general secretary.

Code of Ethics (Articles 5-8)

Art. 5 – Particular rules
Outside the normal procedure for the assignment of files, the employee and consultant shall neither solicit nor receive communications, nor send unauthorised letters. The employee and consultant shall only attend formal and informal meetings related to office activities and to which they are authorised to attend. Moreover they shall avoid unauthorised, direct or indirect, contact with recipients related to the acts and measures adopted, or with those who provide or intend to supply goods or services to the office. The participation of employees and external consultants in conferences, seminars and debates is authorised by the general secretary on the basis that the criteria of transparency, competence, opportunity and turnover are met. This is also subject to a declaration regarding the amount of a possible reimbursement, token or remuneration received for any reason, or the use of certain benefits.

Art. 6 – Conflict of interests
The employee and consultant works to prevent situations of conflict of interest at Osint Centre ltd., informing the Operations Manager of any interests, including those of an economic nature, that they, their spouse, their relatives within the fourth degree or cohabiting persons, have in their activities or their decision-making. The employee and consultant nevertheless abstain from participating in activities or decisions that determine conflict of this kind, providing the general secretary with any further information requested. The employee and consultant refrain, for a period of at least two years, from dealing with issues pertaining to Osint Centre ltd., which may involve the interests of previous business partners or, when authorised, previous employers. In any other case, the employee and consultant must abstain where serious grounds or a serious enmity exist or when one’s intervention to resolve the matter which there are serious reasons of convenience or in which, also because of a serious enmity, one’s participation in the handling of the matter may generate distrust in the impartiality of Osint Centre ltd.. Whilst taking on external assignments or activities, the employee and consultant must promptly inform the Manager of the Operations Office of any contact made with parties who are interested or potentially interested in our work at Osint Centre ltd. This code ensures that the employee and consultant who no longer work at the office are not in a ‘conflict of interest’ situation with Osint Centre ltd., for a period of at least two years.

Art. 7 – Confidentiality
The employee and consultant respect professional secrecy and keep the information and updates learned in the practice confidential, in keeping with the laws and regulations regarding transparency. The employee and consultant are bound by a duty of confidentiality even after leaving the practice. In particular, the employee and consultant do not provide information on preliminary, inspection or investigation activities at Osint Centre ltd., and do not release information concerning the deeds and provisions previously communicated to parties. The employee and consultant only consult the deeds and files to which they are authorised to access, using them in accordance with their official duties, and permitting access to those who are entitled, all in compliance with the provisions of the office. The employee and consultant prevent the possible dispersion of information by observing the security measures in place, guarding in an orderly and caring manner the entrusted deeds, thus avoiding the making of unnecessary copies.

Art. 8 – Relations with the press
In regards to the activities of Osint Centre ltd., the employee and consultant must not have relations with the press or other media, abstaining from any public statement that may negatively affect the image of Osint Centre ltd. If explanations or information need to be provided by the press or an other form of media, the Legal Affairs Office will be promptly informed. Relations with the press and information providers are based on the criterion of equal treatment regarding the timing of news dissemination.