This Anti-Corruption Policy (the "Policy") defines the principles and rules that P-LAB (hereinafter "the Company") and its Sole Director, Matteo Cremonesi (hereinafter "the Sole Director"), adopt to prevent, identify, and combat any form of corruption, whether active or passive, in accordance with applicable Italian legislation (Law 190/2012, Legislative Decree 231/2001, and subsequent amendments and additions) and international best practices.

The Company, although small and operating in the IT consulting and software development sector primarily in Northern Italy, recognizes the importance of an ethical and transparent work environment. This Policy aims to:

Promote a culture of integrity and honesty within the Company and in relationships with third parties.

Prevent the commission of corruption offenses, both by employees and external parties acting on the Company's behalf.

Protect the Company's reputation and interests.

Ensure compliance with applicable laws and regulations.

This Policy applies to all employees, collaborators, directors, consultants, and anyone acting on behalf of the Company, regardless of their role, hierarchical level, or type of contractual relationship. It is each individual's responsibility to fully understand and comply with this Policy.

For the purposes of this Policy, corruption includes, but is not limited to:

Offering, promising, or giving money or other benefits (tangible or intangible) to a public official, public service representative, or private individual, in order to induce them to perform or refrain from performing an act contrary to their official duties or the principles of loyalty and fair dealing.

Requesting or accepting money or other benefits from a public official, public service representative, or private individual, in exchange for performing or refrain from performing an act contrary to their official duties or the principles of loyalty and fair dealing.

Extortion, embezzlement, misappropriation, abuse of office, and all crimes related to public administration.

Favoritism, nepotism, and exchanges of favors that may constitute an illicit advantage.

The Company is committed to:

Zero Tolerance: The Company adopts a zero-tolerance policy towards any form of corruption.

Transparency: All operations and transactions must be conducted transparently, accurately, and verifiably.

Integrity: Every decision and action must be guided by principles of integrity and honesty.

Conflict of Interest: Operating in situations of conflict of interest that could compromise objectivity and loyalty to the Company is prohibited.

Gifts, Presents, and Hospitality:

It is prohibited to offer, give, receive, or promise, directly or indirectly, gifts, presents, favors, benefits, or other benefits that could be interpreted as seeking an undue advantage or that exceed normal business practices and modest value limits.

Any gifts or benefits received from third parties must be promptly reported to the Manager (see point 6).

Only gifts or hospitality of a symbolic or modest value are permitted, and they must not influence business decisions or create the appearance of improper influence.

Political Contributions and Charitable Donations: The Company does not make contributions to political parties or political candidates. Donations to charities must be transparent, documented, and must never be used as a vehicle for corruption.

Due Diligence: The Company is committed to conducting adequate due diligence on business partners, suppliers, consultants, and other third parties with which it interacts, in order to mitigate corruption risks.

The Sole Director: Has the ultimate responsibility for ensuring the implementation and effectiveness of this Policy, promoting its awareness and compliance among all staff.

All employees and collaborators: Are required to read, understand, and comply with this Policy. They must act with integrity and promptly report any violation or suspected violation.

The Company encourages reporting any violation or suspected violation of this Policy. Reports can be made to the administrative manager by sending emails or requesting a private interview.

The Company guarantees maximum confidentiality of the identity of the whistleblower and protection against any form of retaliation or discrimination, in compliance with current legislation on whistleblowing (Legislative Decree 24/2023). Reports will be treated promptly and seriously.

The Company is committed to providing adequate training and awareness to all staff regarding the principles and provisions of this Policy, the risks of corruption, and reporting procedures. Training will be provided upon hiring and updated periodically.

Any violation of this Policy will be subject to disciplinary action, in accordance with the applicable National Collective Bargaining Agreement (CCNL) and applicable law, which may include, depending on the severity of the violation, dismissal for just cause, without prejudice to the Company's right to take legal action for compensation for damages suffered.

This Policy will be reviewed and, if necessary, updated periodically by the Administrator to ensure its effectiveness and adequacy with respect to the evolution of the regulatory framework and company activities.

For any questions or clarifications regarding this Policy, please contact the Administrator or the administrative representative at the email address amministrazione@pec.p-lab.it