Code of ethics
Hangar Design Group srl

This Code of Ethics (hereafter also referred to as “Code”) encompasses all the founding values, principles and behavioural standards that guide the work of Hangar Design Group on the market and conveys the commitment and ethical responsibilities that shall be assumed by all those who are an active part of the company.

1. Recipients of the Code
The Code of Ethics shall be observed in all the activites and behaviours that are perpetrated in the work environment by Partners, Members of the administrative boards, Employees and Collaborators of Hangar Design Group, who are morally committed to spreading its values and ensuring its application.

2. General Principles
This Code of Ethics defines the guidelines and general duties that must be assumed on a daily basis to ensure a diligent, accurate and fair work of all the active parts that collaborate with Hangar Design Group, as well as the smooth functioning and management of the company.
The Code of Ethics aims at improving the efficiency and righteousness of internal and external relations, in order to consolidate the reputation and good name of the company and to optimize all the business activities, for the benefit of the corporate image and economic stability, on the basis of these binding criteria:

• quality criterion that shall be at the base of each result, which must be achieved using technical and professional skills and the highest planning and operational standards;
• customization criterion that determines the relationships with customers, to whom made-to-measure solutions shall be guaranteed, taking their expectations and the peculiarities of their business and/or project into account;
• discipline and professional ethic criterion, principles that shall be observed in the daily work routine;
• innovation criterion, which is fulfilled with the research and application of solutions that can produce renewal and progress;
• autonomy criterion that leads each business activity, which shall not be bound by prejudices and/or obligations, as long as it complies with the law and norms therein described.

Hangar Design Group is as well committed to respecting the personality and professionalism of each Partner, Member of the administrative boards, Employee and Collaborator, as long as it complies with the norms and values therein listed.

3. Honesty and execution of the assigned tasks
Partners, Members of the administrative boards, Employees and Collaborators of Hangar Design Group shall be diligent, efficient, fair, loyal and honest while executing their daily professional tasks, using the tools provided by the company, making the most of the time they have, in accordance with the applicable legal requirements, the norms listed in this Code and the company’s objectives. Their involvement in illegal activities or actions that can discredit the image and reputation of Hangar Design Group is forbidden.

4. Representativeness
Hangar Design Group’s reputation, standing and image shall be protected, not only offline, but also online and, in particular, on social media, as these are the founding values that allow the company to establish and maintain relationships of trust with new and old customers. This is not limited to professional environment, but Partners, Members of the administrative boards, Employees and Collaborators are asked to behave respectfully and not in a way that can be offensive of the social sensitivity outside of the workplace as well, in order not to make interpersonal relations complicated and spread news or other elements that are detrimental to the company’s reputation.

5. Expertise
Partners, Members of the administrative boards, Employees and Collaborators of Hangar Design Group are committed to making use of their expertise, knowledge and experiences, which shall be kept constantly updated, in order to increase the quality of their working activities and improve their personal professionalism.

6. Impartiality
It is deemed necessary to guarantee that each person who comes in contact and establishes a relationship with Hangar Design Group si treated fairly and evenly. Consequently, resorting to any kind of discrimination, based on age, gender, sexual orientation, nationality, health condition, political opinion and/or religious beliefs, is forbidden. Each opinion and judgement shall be expressed as objectively as possibile and not distorted by personal interests or improper influence.

7. Conflict of interest
Employees and Collaborators are forbidden to carry out a work activity that supports competitors, especially assuming the role of consultant or member of the administrative board for competing companies and associations and/or working fro a customer or supplier of Hangar Design Group, receiving money, favors or other services in return. Employees and Collaborators shall as well pre-emptively communicate the emerging of situations or employments, for which they have interests in contrast with those of the company or its clients, and cases where important reasons of selfinterest are involved to their superiors.

8. Confidentiality, privacy and copyright
Partners, Members of the administrative boards, Employees and Collaborators of Hangar Design Group are obliged to ensure complete confidentiality in relation to information or news about the company, their superiors, their clients and/or other partners, employees and collaborators, they learn during the execution of their tasks in the work environment; They are committed to respecting the professional secrecy, acquiring and using data that are exclusively necessary to accomplish their tasks with procedures that are consistent with the company’s methods and norms, preventing third parties from becoming acquainted with these data, without prior authorization; they are obliged to arrange business documents and information in an orderly manner so as to allow the subjects that are entitled to have access to them to have a comprehensive and accurate framework.
It is strictly forbidden for Partners, Members of the administrative boards, Employees and Collaborators to use under any form and with any modality, for any purpose, even personal, intellectual property and/or any other materials protected by copyright, with intellectual and/or industrial property rights of Hangar Design Group or third parties, without the consent of the company. Business, strategical, economic, accounting, management, operational and commercial plans, projects, investments, information related to employees, performance and productivity benchmarks, company agreements and commercial contracts, the production’s know-how, the development and commercialization of services and patents, corporate manuals, portfolios, performed and planned but not realized works, the database and the documents included in the general database and in business servers are protected by a confidentiality obligation.

9. Use and protection of the company’s assets
Employees and Collaborators are forbidden to use corporate assets or services offered by Hangar Design Group outside the working environment and/or for personal purposes, without prior authorization. They are committed to protecting and preventing the damage of physical and material corporate assets (computers, printers, equipment, cars, infrastructures) and the disclosure of intangible assets (confidential information, know-how, technical expertise). The use of these assets must only be suitable for the execution of professional tasks and/or with purposes that are authorized by superiors. At last, this Code establishes that Partners, Employees and Collaborators are forbidden to perform further tasks and/or activities that are not consistent with their organizational responsibilities during working hours.

10. Use of IT Systems
Partners, Members of the administrative boards, Employees and Collaborators of Hangar Design Group are committed to behave properly and transparently while using any IT or telematic system and refraining from activities that can:

• cause the alteration, suppression or fraudolent manufacture of electronic documents that could assume probative value;

They shall not:

• illegally gain access to networks and IT or telematic systems in order to appropriate, modify or delete data, documents and information;
• access websites that are not consistent with the execution of the assigned tasks, join Forums for private reasons, use chat line/online boards and/or register to guest books even using pseudonyms (or nicknames);
• publish their passwords and access codes;
• make copies of licensed programs for private and business purposes or in favor of third parties.

At last, they shall:

• use only their password and access code. Both the identification number and password are strictly personal tools, whose use is up to the responsibility of each user.

11. Relationships between Partners, Members of the administrative boards, Employees, Collaborators and Consultants
The principles of civil cohabitation shall lead the relationships between Partners, Members of the administrative boards, Employees, Collaborators and Consultants, who must act with mutual respect for rights, personalities and peculiarities of each subject.

12. Relationships with Customers
Relationships with customers shall always be loyal, transparent, confidential, kind and professional, in order to strengthen relationships of trust with them and to safeguard the good name and reputation of Hangar Design Group. Partners, Employees and Collaborators are required to keep themselves well-informed and updated so that they are able to provide satisfying and competent answers and comprehensive and understandable information. The acts of courtesy towards customers shall always be appropriate and measured, so as not to promote misunderstandings and/or negative interpretations that conceive them as actions that aim at acquiring improper advantages.

13. Violation of the Code of Ethics, Monitoring and disciplinary processes
What stated in the Code of Ethics is forming part of the contractual obligations of Employees and Collaborators. Therefore, the violation of the principles and standards described therein may constitute a breach of contract and Hangar Design Group has the power to impose measures or penalties or to rescind the contract in the foreseen forms, in the most serious cases. All daily activities can be subjected to internal controls and the definition of a control system is included among the responsibilities of each level of the company structure. This means that all the Partners, Employees and Collaborators are required to ensure the proper functioning of such control system. In the event of verified fraud, theft, omission, forgery, alteration, misuse of confidential information and misappropriation of physical and/or immaterial assets, Hangar Design Group will take legal action and disciplinary measures against the subjects involved.

14. Representativeness
Hangar Design Group’s reputation is an immaterial asset of great value that enables the Company to create and cultivate trust relationships with all its stakeholders. As a consequence, all the activities in the Company must be carried out with professional commitment and rigor. Each employee shall provide a professional contribution matching the assigned responsibilities and must act to safeguard the prestige of Hangar Design Group.
Therefore, behaviors outside of work that are particularly offensive to civil sensitivity and make interpersonal contacts in the working environment reasonably difficult will be considered relevant. Each employee is required to contribute personally to the conservation of a work environment that is respectful of other people’s sensitivity.
Those who will:

• work under the effect of alcohol or drugs
• consume or transfer drugs at any title during their work performance will be considered as being aware of the risk they cause.

15. Protection of dignity. Harassment in the workplace
Hangar Design Group is committed to provide trust and equal work opportunities to everyone, without discriminations based on ethnicity, religion, opinion, nationality, sex, physical condition, age, social conditions, so as to ensure a fair and non-discriminatory treatment based on merit criteria and on values of equality, tolerance and mutual respect.

Competent functions shall:

• adopt criteria related to merit, competence and strict professionalism for any decision concerning the collaborators;
• take care of choosing, hiring, training, remunerating and managing collaborators without any discrimination;
• create a work environment in which personal characteristics are not a source of discrimination;
• Hangar Design Group expects that employees at all levels will help keep the Company in a climate of mutual respect for everyone’s dignity, honor and reputation.
• In the working environment no behavior or conduct that results in sexual harassment is allowed, by which term is meant;
• the subordination of decisions determining a person’s career and working conditions to the concession of sexual favors;
• proposals of private interpersonal relationships, despite the recipient’s clearly expressed or reasonably evident distaste, which could upset the serenity of the victim with negative consequences on their work performance.

16. Use of time and Hangar Design Group’s business assets
Collaborators are required not to undertake and cultivate activities, investments or interests that may affect the integrity or the name of Hangar Design Group or that may materialize in acts of corruption, favoritism, solicitation or any other collusive and illegal behavior, through third parties as well, in order to obtain a personal or career advantage for themselves or for others. Hangar Design Group recognizes and protects the right of its employees to participate in investments, business or activities other than the Company’s, within the limits permitted by law and in accordance with the obligations arising from the employment relationship with Hangar Design Group.

In any case, Hangar Design Group’s employees are required to carry out their own personal and/or family business and/or economic activities, if any, in perfect non-competition with the interests of the Company and in full compliance with the Code’s norms. Any situation that may constitute or cause a conflict of interest must be immediately communicated to superiors.

Employees can not, during their working hours, perform other activities that are inconsistent with their duties and organizational responsibilities. Use of corporate assets, such as spaces, equipment and confidential information of the Company, is not permitted for any kind of use and personal interest.

17. Use of insider information
Hangar Design Group’s staff, in the common fulfillment of its business activities, may disclose, as already described in the preceding paragraphs, confidential information relating to Hangar Design Group. The use of this information for personal, private, economic purposes not only constitutes a morally and ethically incorrect behavior, but also a violation of current legislation and as such is punishable.

18. Management and protection of copyright
Hangar Design Group grants the absolute ban on its employees to use, in any form and/or way and for any purpose, even for personal use, intellectual property and/or material protected by copyright and any right to intellectual and/or industrial property (including, but not limited to, trademarks, designs, patents for invention and utility models, secret information), including image rights and the right to name, without the consent of the holders of the rights and/or those who have the legitimate availability. Collaborators are required to to ask for the necessary consent for the use of protected works and materials.

19. Fairness in business
Any employee who has business relationships with third parties must relate to them ethically, fairly, and correctly. These principles are valid for customers, suppliers, consultants, and individuals who carry out any business directly or on behalf of the Company.

Specifically, the selection of suppliers and the formulation of the terms and conditions for purchasing goods and services for Hangar Design Group is dictated by values and parameters of competition, objectivity, fairness, impartiality, fairness, price, quality of goods and service, assistance warranty and in general by an accurate and precise evaluation of the offer.

In the choice of suppliers, no undue pressures are allowed to encourage a supplier rather than another and undermine the credibility and trust the market places in Hangar Design Group regarding transparency and rigor in law enforcement and business procedures. In dealing with customers, suppliers, or third parties, no money or gift offerings that are intended to obtain real or apparent benefits of various kinds (eg, economical benefits, favors, recommendations) are allowed. In any case, business courtesy must never be carried out in circumstances such as to give rise to suspected illegality. If the staff is in the condition of receiving confidential information, they must handle them with the utmost confidentiality to prevent the Company from being accused of misappropriation and misuse of information. Hangar Design Group’s employees are not allowed to use confidential data and information received by third parties, unless Hangar Design Group has entered into an agreement with third parties for the use of such information.

20. Entry into force
The Code of Ethics comes into force as of April 15th, 2017.
Any change or integration must be approved by the Board of Directors and it cancels and replaces, from the date of its issue, all versions previously issued. The Code of Ethics does not replace existing and future business procedures that continue to be effective insofar as they are not in conflict with the Code itself.