Code of Ethics

1. Preamble and scope

The Code of Ethics applies to directors, shareholders, employees, collaborators, consultants and any party with an ongoing or occasional relationship with Medicalware. The company promotes awareness of the Code among all addressees and requires its full observance as a condition of any working or professional relationship.

The Code complements applicable law and any organizational, management and control models adopted pursuant to Italian Legislative Decree 231/2001.

2. Core values

Medicalware's activity is inspired by the following non-negotiable values:

• Integrity and honesty: acting fairly, loyally and in good faith in all relationships, internal and external.
• Transparency: communicating clearly and truthfully, avoiding ambiguity and material omissions.
• Respect for the person: protecting the dignity, freedom and equality of every individual, without discrimination of any kind.
• Competence and professionalism: pursuing technical excellence and continuous learning as the foundation of the value delivered.
• Legality: complying with laws, regulations and internal procedures as a prerequisite for any activity.
• Sustainability: making decisions that take into account economic, social and environmental impact over the medium and long term.

3. Relationships with clients

Medicalware is committed to providing high-quality services and products that meet client needs and expectations, and to building lasting relationships based on trust. In every interaction we guarantee:

• Clear and complete information, including during pre-contractual phases;
• Confidentiality of information and data received from the client during the relationship;
• Equal treatment and absence of discrimination;
• Timely and fair handling of complaints and reports.

4. Relationships with employees and collaborators

People are Medicalware's most important asset. The company is committed to:

• Selecting personnel based on objective criteria of competence, experience and merit, without discrimination of gender, age, sexual orientation, religion, political opinion, nationality or personal condition;
• Promoting an inclusive, safe and respectful work environment, free from harassment, mobbing or undue pressure;
• Fostering professional growth through training, autonomy and accountability;
• Ensuring proper management of the employment relationship in compliance with applicable law and reference collective agreements;
• Protecting workers' health and safety, including in remote work settings.

5. Relationships with suppliers and partners

Suppliers are selected based on objective assessments of quality, reliability, price, technical capability, security and sustainability. Medicalware:

• Rejects any form of pressure, favoritism or preferential treatment not based on objective criteria;
• Honors its commitments punctually and expects reciprocity;
• Requires suppliers and partners to comply with the principles of this Code, in particular regarding legality, anti-corruption, confidentiality and labor protection.

6. Relationships with Public Administration and anti-corruption

Relationships with public administrations, supervisory authorities and institutions in general are conducted with the utmost fairness, transparency and cooperation.

Medicalware condemns any form of corruption, active or passive, extortion, trading in influence and any practice intended to unduly influence the decisions of public officials, persons in charge of public services or private counterparts. It is strictly forbidden to offer, promise or accept money, gifts, benefits or other advantages that could appear aimed at obtaining preferential treatment.

Gifts or acts of courtesy are permitted only if of modest value, in line with commercial practice, and such that they cannot be interpreted as instruments of undue influence.

7. Confidentiality and data protection

All addressees of the Code are required to maintain confidentiality regarding information acquired in the course of their duties, in particular:

• Personal data of clients, employees, collaborators and third parties, processed in compliance with Regulation (EU) 2016/679 (GDPR) and applicable national legislation;
• Commercial, technical, financial and strategic information about the company or its partners;
• Know-how, source code, technical documentation and intellectual property.

The use of such information is permitted exclusively for purposes connected with the relationship with Medicalware and may not continue beyond the termination of the relationship. For further details please refer to the Privacy Policy.

8. Conflicts of interest

Addressees of the Code must avoid any situation of conflict, even merely potential, between personal interests and the interests of the company. Specifically, they are required to:

• Promptly disclose to the company any situation that may constitute a conflict of interest;
• Not use information acquired in the course of company activities for personal gain or for the benefit of third parties;
• Abstain from decisions in which a material conflict exists.

9. Communication and use of company tools

External and internal communication must be truthful, clear and respectful. Company tools (email accounts, system access, devices, source code) are assigned for professional purposes and must be used in compliance with internal policies, IT security rules and this Code.

Any use of company tools for unlawful activities, activities harmful to the dignity of others, or in violation of third-party intellectual property rights, is prohibited.

10. Reports

Anyone who becomes aware of a violation, even merely alleged, of this Code, of laws, regulations or company procedures may submit a report by writing to info@medicalware.it or, for greater confidentiality, to medicalware@pec.libero.it.

Reports are handled with the utmost confidentiality, in compliance with Italian Legislative Decree 24/2023 (“Protection of persons who report breaches”) and applicable legislation. Medicalware guarantees protection of good-faith reporters against any form of direct or indirect retaliation.

11. Final provisions

Compliance with the Code of Ethics is an essential condition of any relationship with Medicalware. Violations may result, depending on their severity, in disciplinary measures for employees, termination of the contractual relationship for collaborators, consultants, suppliers and partners, in addition to any civil and criminal consequences provided for by law.

This Code may be updated at any time. The current version is the one published on this page; the date of the last modification is shown at the top of the document.