Code of Ethics, Confidential information, privacy protection and Insider trading

7 – Confidential information, privacy protection and Insider Trading

7.1 Confidential information and privacy protection

The Group’s activities constantly require data, documents and information regarding business negotiations, procedures, transactions and contracts to which the Group is party to be obtained, retained, processed, disclosed and circulated.

The Group databases may contain, moreover, personal data protected by privacy laws, data that may not be divulged abroad and data whose disclosure could cause damage to the Group itself.

Each Employee is thus required to safeguard the private and confidential nature of the information acquired as part of his/her work duties, and – more specifically – to comply with the confidentiality clauses requested by Clients and other counterparties.

All information, knowledge and data acquired or processed by Employees by way of their duties belong to the Group and may not be utilized, disclosed or divulged without prior and specific authorization being granted by a superior.

Each Employee shall:

  • obtain and process only the data that is necessary and directly related to his/her duties;
  • retain said data in such a way that outside third parties are prevented from becoming aware of it;
  • disclose and divulge data as part of procedures that are pre-established by the Group or with prior approval of the competent person;
  • ensure that there are no confidentiality-related restrictions by virtue of relations of any kind with third parties.

The Group for its part undertakes to protect information and data relating to its Employees and to third parties, and to prevent said information and data from being used improperly.

To ensure that the privacy of all Employees and Collaborators is respected, the language used in communications and demand of personal data must be clear and unequivocal so that such persons can understand the request, the processing and storage of data. All standards adopted prohibiting to collect/disseminate personal data without the consent of the employee, except as required by law.

It does not include any investigation of ideas, preferences, privacy of workers.

7.2 Insider trading

All Employees and external Collaborators who are not bound by an employment contract shall observe both domestic and international laws relating to insider trading.

With this in mind, price-sensitive information is of particular importance. Said information is to be disclosed to third parties – in accordance with the procedures adopted by the Group – solely by those persons authorized to do so, and in any event in conformity with current legal provisions and pursuant to principles of the equality and contextuality of information.

No Employee or Collaborator not bound by an employment contract is to gain benefit of any kind (be it direct or indirect, personal or wealth-related) from using confidential information, where said information is not available within the public domain.

 

  1. General Principles
  2. Ethical Principles
  3. Relationship with employees and collaborators
  4. Relationship with third parties
  5. Staff and workplace policies
  6. Corporate governance
  7. Confidential information and privacy protection. Insider trading

Sofinter Group Code of Ethics

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