The code of ethics







INTERSISTEMI Italy SpA is a company that provides services for public (Pac and Pal) and private (banking industries and services), medium and large, entities.

The Italian regulatory intervention, in particular the legislative decree n. 231 /01 on administrative liability of companies for offenses committed by their members, employees and collaborators, has made ​​essential to codify the principles of lawfulness, fairness, honesty and transparency, under which have to conformed the conduct of all persons who have to operate with INTERSISTEMI.

INTERSISTEMI therefore decided to adopt the “Code of Ethics” (the Code): a document that collects in an official and organic set the principles of conduct of the company in relation to major stakeholders, in some cases even to the reinforcement of legal regulations force, directing the different subjects on the lines of action to be taken and the ones to avoid, identifying the responsibilities and possible consequences in terms of sanctions.

The organizational model and the internal procedures, adopted by Intersistemi for the conduct of its activities in general and, in particular, those of which mention is made in the following chapters, conform to the rules contained in this Code.




The above-mentioned principles and provisions of the Code are binding for administrators, for people related to employment relationships and for all those who operate for Intersistemi, whatever the relationship that binds them the same, hereinafter all referred to by the term “Recipients”.




3.1 Ethics and business


Transparency, fairness, respect the business rules represent the set of distinctive values ​​that characterize the activities and relationships of Intersistemi and constitute an essential basis of any relationship with any third party. These values ​​have to consider as essential to the nature of the services offered and the processed information.


3.2 Aims and Values


The activity of Intersistemi, in pursuing the company’s interests, having always in mind the ethical values ​​that the company adopts, also aims to:

  • enhance the professional knowledge of staff, in a working environment inspired on fairness and cooperation, based on experience in the fields of competence;
  • empower and involve employees and contractors with regard to the specific objectives to be achieved and the methods to be pursued;
  • interpret customer needs, respecting the principles of proper exercise of the activity;
  • pursue business interests with loyal and correct behavior, aiming at the highest levels of professional integrity.


3.3 Compliance with laws and regulations

The company rejects any behavior, even if it put in place in his favor, which is contrary to the law, regulations or the lines indicated in Code.

Intersistemi conducts an appropriate program of training and awareness of the issues pertinent to the Code and carries out monitoring and verification of compliance with current legislation, promoting organizational tools to prevent violations of the laws and ethical principles.



3.4 Confidentiality

Data and information are an integral part of the company’s assets due to the specific sectors in which it operates and the activities carried out.

No confidential information, acquired or developed by the Recipients in the course or on the occasion of their activities, can be used, communicated or distributed to third parties for different aims from institutional purposes.





4.1 Administration and Budget

Transparency, accuracy and completeness of accounting information and its own budget are essential for Intersistemi.

To this end, Intersistemi undertakes to respect the principles enshrined in the Civil Code and the regulations for the sector.

Recipients, involved in administrative and accounting activities, must strictly comply with the procedures, the rules of law and accounting standards.

In particular, the accounting records and documents are based on accurate, comprehensive and verifiable information and reflect the nature of the transaction to which they refer. They are stored with the same care for the eventual subjection to verification.
Recipients aware of any omissions, errors or falsifications of or accounting records must inform their superiors and according to the seriousness of the Supervisory Board.

Recipients in preparing the financial statements should operate prudently, supported by the knowledge of the accounting techniques or more specific the sector concerned and in any case with the diligence required to experts in the sector.



4.2 Illegal behaviors

Intersistemi ordains that the Recipients should refrain from providing or promising to third parties sums of money or other benefits in any form or manner, even indirectly, to promote or further the interests of the company, although subjected to illegal pressure.

They cannot accept for themselves or for other such payments and/or utilities to promote or favor the interests of third parties in dealing with Intersistemi.

We do not allow gifts of significant value, if they are of little value, they must be attributable solely to acts of comity context of ethical business relationships.

In addition, it is forbidden to expose facts that are untrue, omit information, or conceal data in direct or indirect violation of regulatory principles and internal procedural rules, to mislead third parties recipients of this information.

Any cause of action recognized in conflict with the principles of ethics and conduct as defined by this Code must be promptly reported to the Supervisory Board.






5.1 Relations with shareholders

Intersistemi commits to safeguard the corporate assets in relations with its shareholders, using the criteria of sound and prudent management.



5.2 Relationship with employees and consultants

Employees and consultants that operate in Intersistemi, must adhere to the observance of the principles of protection and respect for humans, integrity, dignity, morality, honesty in personal relationships, integration and cross-functional collaboration, sense of responsibility and respect for hierarchical and functional relationships. Employees and consultants, working with resources owned by Intersistemi, are also expected to abide by the rules set out in the document entitled “USE OF INFORMATION RESOURCES.


Intersistemi constantly keeps informed employees about the company directives through the most appropriate channels of information.



5.3 Relationships with customers

Intersistemi ordains that recipients must adopt behaviors aimed to meeting the just requirements of the customer, and to strengthen the relationship in accordance with local regulations.



5.4 Relations with suppliers

Intersistemi selected with special care providers in compliance with the principles of transparency, impartiality and fairness, ascertaining the actual technical and professional competence and appropriate means/tools to cope activity commissioned.

Intersistemi has agreed to enter into contracts with suppliers termination clauses in case of serious violations of the Code precepts.



5.5 Relations with the Public Administration

Reports Intersistemi with the Public Administration are based to the full observance of the laws and regulations, respecting the character public function.
Intersistemi ordains that it is prohibited to recipients promise or deliver money to public officials and civil servants in any form, directly or indirectly, to induce or facilitate the performance of an official act or contrary to official duties of the Public Administration, placed in be to promote interest/benefit of Intersistemi.
Anyone who receives explicit or implicit requests for benefits of any kind from the Public Administration, also with unlawful pressure, must inform the Supervisory Board.
The provisions listed do not apply to expenses, ordinary and reasonable or the gifts of modest value, which correspond to normal custom, provided they do not infringe the provisions of the law.
Recipients should not unduly procure any other kind of profit either for himself or for Intersistemi or for third parties, to the detriment of the Public Administration, with trickery or deception.
Therefore, Intersistemi ordains that the Recipients should not under any circumstances:
1 . obtaining illicitly to Intersistemi grants, loans or other funds of the same type issued by the Public Administration, through the use or presentation of false or misleading documents , or omission of required information;
2 . using grants, subsidies or funding of Intersistemi, for different purposes from those for which they were granted.


For all the facts constituting the offense, the recipients must however inform the competent Judicial Authorities.




Software engineers shall commit themselves to make the analysis, specification, design, development, testing and maintenance of software a respected profession with beneficent effects. In accordance with their commitment to health, physical security (safety) and to the public welfare public, software engineers shall adhere to the eight principles listed below:

1 . Public. Software engineers shall act consistently with the public interest.

2 .Client and employer. Software engineers shall act in a manner consistent with the interests of their client and employer, in accordance with the public interest.

3 .Product. Software engineers shall ensure that their products and related modifications are applied to the highest professional standards.

4 .Judgment. Software engineers shall maintain integrity and independence in their professional judgment.

5 . Management. Managing and leading software engineers shall subscribe and promote an ethical approach to the management of the development and maintenance of the software.

6 . Profession. Software engineers shall advance the integrity and reputation of the profession consistent with the public interest.

7 . Colleagues. Software engineers shall be fair and supportive towards their colleagues.

8 . Themselves. Throughout the duration of their employment, Software engineers shall continue own education on the practice of the profession and shall promote an ethical approach to it.




II personal computer entrusted to the employee is a work tool. Everyone is responsible for the use of IT equipment received in assignment. The detections of problems relating to malfunctions (both software and hardware) shall be immediately reported to the competent office via e-mail.

Any use not related at work can trigger outages, maintenance costs and, above all, security threats.

It does not allow the activation of the power-on password (bios) without prior authorization from the Intersistemi SpA.

Users cannot modify the hardware and software set up on your PC, without the prior express permission of the system administrator of Intersistemi SpA.

The personal computer must be turned off every night before leaving the office or in case of prolonged absences from the office unless expressly authorized by the line manager or system administrator.

The information stored in the IT system should be only those required by law or necessary to work.

Periodic cleaning (at least every six months) of the archives is a good rule of thumb, with deletion of obsolete or unnecessary files (.tmp). Particular attention must be given to the duplication of data. It is absolutely to avoid redundant storage.

The protection of local management of data on workstations, personal – personal computers that run locally documents and/or data – is responsibility of the end user that will have to carry out, with appropriate intervals, on network media bailouts, made ​​available at the work place. However, it is banned the use of removable storage media for storing sensitive data.

The local management of data must disappear to be replaced by management centralized on the server.
It is not allowed to install programs other than those authorized by the Business Information System.

It is not permitted to reproduce or duplication of computer programs pursuant to Law 128 of 21.05.2004.

The operators of the Information System may at any time proceed to remove every file or application may that they considerer to be hazardous to the safety on both the PC and on network drives.


7.1 Using Intersistemi SpA Network 

A password protect the access to the corporate network; for the access it must be used their own personal profile (username and password).

It is forbidden to use the corporate network for purposes not explicitly authorized.

It is forbidden to network workstations except upon explicit and formal permission of the system.

It is forbidden to share folders over the network is equipped with a password and without password, except upon explicit and formal permission of the system.

It is forbidden to monitor what passes through the network.

It is prohibited an unauthorized installation of modems that take advantage of the communication telephone system for access to external or internal databases of the company.


7.2 Password Management

The password for accessing the network, to the various programs in the network for the processing of data and Internet, are allocated by Intersistemi SpA.

The user is obliged to keep the password to the network and systems and any other information related to the authentication process with utmost secrecy. The user is required to log off the system whenever it is forced to be absent from the room in which is located the workstation or in the event that he is not able to supervise access to the same: leave an unattended computer connected to the network can be due to usage by a third party without there being the possibility to prove later the undue use.

The password must be replaced immediately, informing the Intersistemi SpA, if you suspect that it has lost its secrecy.



7.3 Using laptops

The user is responsible for the laptop assigned by the Company and he must guard it with care both while traveling or during use in the workplace.

The rules for the use of network-connected PCs are the same for laptops, with particular attention to the removal of any files processed on the same before delivery.

The laptops are used outside, in the event of removal, must be kept in a safe location.

The laptop should never be left unattended and must be stored on disk files only strictly necessary.



7.4 Using E-mail

Enabling e-mail is done at the same time the activation of the employment contract with the Intersistemi SpA.

The mailbox, assigned by the Company, is a work tool. People, assigned one of the mailboxes, are responsible for the proper use of those (Article 615 paragraph 5 et seq. Penal Code).

In the case of unknown senders or unusual messages, it needs to delete messages without opening them to avoid the risk of be infected by viruses.

In the case of messages from senders known but which contain suspicious attachments (files with extension .exe .scr .pif .bat .cmd ), the latter not must be open.

Prevent the uncontrolled spread of “Chain letters” (messages widespread distribution and multiplied) limits the efficiency of the mail system.

Use, in the case of sending large attachments, compressed formats (.zip*.rar*.jpg).

In case you need to send a document outside the company it is preferable to use a format write-protected (for example, Acrobat *.pdf).

This specific software is provided by Intersistemi SpA (Office 2007 SP2 that allows the backup in PDF format).

Registration for external “mailing list” is granted only for professional reasons; before enrolling, it should check in advance whether the site is reliable.

The mailbox must be kept in order, deleting unnecessary documents and especially bulky attachments.

To transfer files within the Intersistemi SpA it can use e-mail, with attention to the size of attachments that should never exceed 15 MB.

It is mandatory to check the files attachment e-mail before their use (do not download executable files or documents from Web sites or Ftp not known).

Intersistemi SpA does not allow redirection of the operations or the business e-mail.



7.5  Use of the Internet and related services

Enabled PC for surfing the Internet is a business tool necessary for the performance of their work.

It is absolutely forbidden to surf the Internet for reasons other than those strictly work-related itself.

It cannot be used for private modem connection to the network.

The user cannot download free software (freeware) and shareware taken from Internet sites, unless expressly authorized by Intersistemi SpA.

It is forbidden the participation in non-professional Forum, the use of chat lines (excluding eligible instruments), electronic bulletin boards and social networking also using pseudonyms (or nickname).



7.6 Virus Protection

Each user must behavior to reduce the risk of attack on the company computer system by viruses or by any other aggressive software (for example, do not open suspicious emails or attachments, do not surf the non-professional sites etc …).

Each user is required to check the presence and the orderly functioning and updating of anti-virus software company.

In the event that the antivirus software detects the presence of a virus, which has failed to clean up, the user must immediately: suspend any processing in progress and without turning the computer report this to the manager for the safety of Intersistemi SpA.

Each storage device from the holding must be verified by antivirus program before its use, and in If a virus is not eliminated by the software, should not be used.




Intersistemi, as part of activities to adapt its organizational model to the needs expressed by Legislative Decree no. 231/01, has set up a Supervisory Board.

This Board will be to verify the proper functioning of the organizational model and respect by the employees of the rules contained in the Code, proposing the possible update.

This Committee will report regularly to the Board of Directors on its activities.




The provisions of this Code are an integral part of the contractual obligations of recipients or persons having business relations with Intersistemi.

Any violation of the Code may constitute a breach of contract, with all the legal consequences, in order to terminate the contract or appointment and possible damages.




This Code has been approved by the shareholders on request of the Act, by resolution of 29/04/2009.


INTERSISTEMI strives to raise awareness of this Code pursuant to Legislative Decree no. 231/ 01 to all recipients.



Rome, September 1, 2010

The Chief Executive

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