CODE OF ETHICS

OF

THE FOUNDATION "UN RAGGIO DI LUCE ETS"

Table of Contents

ART. 1 Mission of the Foundation “A Beam of Light ETS”

ART. 2 Purpose and Scope

ART. 3 General Principles

ART. 4 Gifts, retributions and other benefits

ART. 5 Involvement in associations and organisations

ART. 6 Conflict of interest

ART. 7 Corruption prevention

ART. 8 Confidentiality

ART. 9 Protection of the image

ART. 10 Staff relations

ART. 11 Relations with the public

ART. 12 Special provisions for management staff

ART. 13 Special Provisions for Foundation Staff Abroad

ART. 14 Codes of Conduct for Civil Society Organisations (CSOs) and other non-profit entities that are

partners of FRL initiatives

ART. 15 Supplementary budget resources (sponsorship and donations)

ART. 16 Respect for the environment and eco-sustainability

ART. 17 Contributions and sponsorships

ART. 18 Accountability for violating the duties of this Code

ART. 19 Notification

ART. 20 Final Provisions

ART. 1
Mission of the Foundation “Un Raggio di Luce ETS”

1. The Foundation “Un Raggio di Luce ETS” (henceforth “FRL” or “Foundation”) is a non-profit organisation pursuing civic, solidarity and socially useful objectives in the field of social and socio-medical assistance, distance assistance, charity, education, training, the protection of human and civil rights, equal opportunities, the culture of legality, the protection and improvement of nature and the environment, the protection of artistic and cultural heritage and international cooperation;

2. The Foundation is a Third Sector Body with legal status registered with the Pistoia Prefecture, Italy, under number 28, Volume V.

ART. 2
Purpose and Scope

1. This Code of Ethics collects and brings together the principles, values and rules that must guide the Foundation’s action and the conduct of the Governing Bodies and all the personnel, managerial and non-managerial, of the Foundation itself;

2. Insofar as they are compatible, the obligations of conduct set out in this code also apply to the collaborators or consultants of the Foundation, working at the National Headquarters (via Franchetti 11, 51100, Pistoia), at the offices abroad and during missions abroad, in order to ensure a responsible, quality service that meets the needs of the local partners;

3. The strength of this Code lies above all in the awareness of the value of these rules and in the sharing by its addressees of the ethical principles of diligence, loyalty, impartiality and care for the collective interest, responsibility and trust;

4. Just as the Foundation requires the addressees of this code to behave in conformity with the prescriptions contained herein, so it asks, in compliance with the principle of reciprocity, that its partners act towards it according to rules inspired by a similar ethical conduct.

ART. 3
General Principles

1. The Foundation shall independently choose the methods and instruments with which it plans and pursues the objectives established in its Statute. The Foundation’s actions shall be conducted in full compliance with the principles of integrity, fairness, good faith, proportionality, objectivity, transparency, equity and reasonableness. The Foundation will take into consideration any new circumstances, changing conditions as well as evolving demands and needs that arise in the Italian society and in the international context. The Foundation acts from a position of independence and impartiality. The Foundation is accountable to its Board of Directors (BoD), Committee for Direction, and Supervisory Board;

2. Integrity means the safeguarding, by the staff and members of the Corporate Bodies of the FRL, of the efficiency, impartiality, independence and confidentiality of the activities. To this end, the adequate professional commitment, checks on administrative and accounting activities, and the protection of the Foundation’s image are all relevant;

3. The Foundation pays particular attention to avoiding and sanctioning any act that may offend the dignity of the human person, pursuing - first and foremost - the prevention and contrast of harassment, abuse and sexual exploitation and the prevention and fight against mobbing, which form an integral part of this Code;

4. The Foundation shall ensure that any diversity is not mocked or discriminated against, either among the staff and members of the Foundation’s governing bodies or towards the public, nor will it hinder the full deployment of the staff’s professional skills and the development of their career prospects;

5. The Foundation pays particular attention to the creation and management of an appropriate environment and workplace in terms of safety and well-being of the staff and those who have access to it, in compliance with the relevant national legislation;

6. The Foundation encourages lifelong staff training in the fields of activity identified by the Statute and grants it within the limits of its budget.

ART. 4
Gifts, retributions and other benefits

1. Gifts and presents are to be understood as those received occasionally by personnel or members of corporate bodies, in the course of their duties, from institutional counterparts and by virtue of normal courtesy and international custom. Such gifts and presents must be of modest value. The modest value must be assessed in relation to the different economic realities of the countries of accreditation and may in any case not exceed the value of €150;

2. Gifts of a value exceeding the limit set forth in paragraph 1, if received in the performance of one’s duties and from institutional counterparts, shall be immediately made available to the Foundation, which may return them or use them for furnishing the national headquarters and offices abroad, whether its own or those of its project partners, or allocate them for initiatives with humanitarian, charitable, assistance and charity purposes or, lastly, when possible, for the Foundation’s service purposes. The gifts and presents received must not in any case compromise the independence of judgement, operational correctness, integrity and reputation of the personnel and members of the Foundation’s Corporate Bodies, and in any case must be such that they cannot be interpreted, by an impartial observer, as aimed at acquiring advantages in an improper manner;

3. No member of the staff or of the Corporate Bodies of the Foundation may give money or provide economic advantages or other types of benefits to persons of the Public Administration or their family members for the purpose of obtaining appointments or other advantages, whether personal or for the Foundation itself.

ART. 5
Involvement in associations and organisations

1. In compliance with the current legislation on the right of association, the staff and the members of the Foundation’s Corporate Bodies shall communicate by email within 10 days to the Secretary General of FRL their membership, affiliation or participation in associations or organisations whose spheres of interest may concern or interfere with the performance of their official activity. This is without any prejudice to the constitutionally guaranteed right of membership in political parties and trade unions;

2. In particular, staff and members of the Foundation’s Corporate Bodies shall not take part in associations, clubs or other bodies of any nature if, for the purpose of membership, they are required to swear an oath or promise to abide by principles, ideologies, duties or obligations that conflict with those covered by the Foundation’s Articles of Association at the time of taking up their duties;

3. The Foundation shall assess the compatibility of admission to or membership of associations or organisations in order to adopt all those measures, such as assignment to another post, obligation to abstain, or turnover, that may be necessary to prevent the possibility that membership, in itself lawful and free, may lead to situations of real or potential conflict of interest;

4. The staff and the members of the Foundation’s Corporate Bodies shall also communicate by email to the Secretary General of the FRL any variations of the declarations mentioned in paragraph 1 of this article within 10 days of their occurrence.

ART. 6
Conflict of interest

1. All the staff and all the members of the Corporate Bodies of the Foundation are required to avoid situations in which conflicts of interest may arise and to avoid taking personal advantage from opportunities they have come to know in the course of the performance of their duties. Nobody who has relations with the personnel or with a member of the Social Bodies of the Foundation must be able to take improper advantage of them by virtue of his or her relationship with the person;

2. All staff and all members of the Foundation’s Corporate Bodies shall notify the Secretary General of the FRL - by email - within 10 days of being assigned to a position, of the existence of a conflict of interest, even potential, of a financial or other nature, with private individuals in any way paid with whom they have or have had relations in the last three years, specifying that they have cautiously avoided relations with said individuals, and:

A. whether in the first person, or their relatives or relatives-in-law within the second degree, spouses or cohabitants still have financial relations with the subjects with whom they have had the aforementioned relations;

B. whether such relationships have occurred or are occurring with persons who have an interest in activities or decisions inherent to the assignment they have been entrusted with.

The FRL Secretary General reports the information to the FRL Board of Directors, which collectively decides whether the abstention from relations with such persons should continue or whether the conditions are no longer applicable. In the event of the FRL General Secretary believing that s/he is her/himself in a situation of conflict of interest, the aforementioned communication shall be sent to the FRL President: he will then request clarifications from the subject in order to assess the situation, and report the information to the FRL Board of Directors; the FRL Board of Directors shall decide collectively whether the abstention from relations with such persons should continue or whether the conditions for abstention are no longer applicable;

3. The same duty of disclosure also applies in the event that personnel and members of the corporate bodies find themselves in a situation of only apparent conflict of interest, i.e. one that can be perceived as such from the outside (e.g. homonymy). The Secretary General of the FRL shall decide on the ways in which the staff and members of the Foundation’s Corporate Bodies shall take steps, as far as possible, to bring the actual situation to light;

4. The aforementioned disclosure obligation shall also apply if the actual, apparent or potential conflict of interest situation has arisen during service. The aforesaid disclosures shall be submitted by means of a self-certification made pursuant to Presidential Decree no. 445 of 28 December 2000, and shall oblige the staff and members of the Foundation’s Corporate Bodies to inform the Foundation itself of any changes that have occurred by email within 10 days of their occurrence;

5. Given that it is up to the Secretary General of the Foundation, the President of the Foundation and the Board of Directors of the Foundation to concretely evaluate individual cases of conflict of interest, the staff, including part-time staff and those who serve in any capacity at the Foundation, are not in any case permitted to carry out activities or work for entities or private individuals, with the object of consulting, preliminary activities, requests of opinions or assessments of a technical nature, the submission of applications, communications, however named, in progress with the Foundation;

6. The provisions relating to extra-institutional activities also apply to personnel with a fixed-term employment relationship;

7. Staff and members of the Foundation’s Corporate Bodies who fail to comply with the requirements of this article shall incur disciplinary liability, save for more serious liabilities envisaged by law;

8. The staff of the Foundation may enrol in professional registers/boards, subject to prior notification to the Secretary General of the Foundation, if the specific legal provisions governing the individual professions allow it, namely that they do not require, as a prerequisite for enrolment, the exclusive exercise of freelance activity. Free professional activity, even on an occasional basis, shall in any case remain precluded for the personnel of the FRL;

9. The staff and members of the Foundation’s Corporate Bodies who have been assigned to management positions must submit, when the appointment is conferred, a declaration on the non-existence of grounds for exclusion and, annually, on the non-existence of grounds for incompatibility. The aforementioned declarations shall be submitted by means of a self-certification made pursuant to Presidential Decree no. 445 of 28 December 2000 - transmitted by email - and shall oblige the official to inform the Foundation of any changes within 10 days of their occurrence. Such communications shall be sent to the Foundation's institutional email address (fondazione@unraggiodiluce.org).

ART. 7
Corruption prevention

1. The personnel and the members of the Corporate Bodies of the Foundation shall maintain a conduct that fully complies with the corruption prevention legislation and, without prejudice to the obligation to report to the judicial authorities, they shall report to their immediate superior any unlawful situations they may become aware of;

2. Personnel and members of the Foundation’s Corporate Bodies shall inform their immediate superior of the existence of criminal or disciplinary proceedings against them for corruption-related conduct;

3. If, for reasons of appropriateness, the personnel and members of the Foundation’s Corporate Bodies consider that they cannot report to their immediate superior, they may report directly to the President of the Foundation and to the Foundation’s Control Body any facts, acts or illegal conduct they have become aware of in the performance of their duties;

4. The Foundation guarantees adequate protection for those who report acts of corruption.

ART. 8
Confidentiality

1. The Foundation guarantees the confidentiality of the information and personal data processed and the protection of the information acquired in the performance of its institutional functions in accordance with Regulation (EU) 2016/679 on the protection of personal data (General Data Protection Regulation - GDPR) and Legislative Decree no. 196 of 30 June 2003 and subsequent modifications and additions, in order to prevent such information from being used for purposes that are different from or contrary to the law or that cause damage to the Foundation;

2. The personnel and members of the Corporate Bodies of the Foundation are required not to use confidential information for purposes not strictly connected with the execution of their work, and to exercise due diligence and care in the use of such information in order to avoid its involuntary disclosure;

3. The personnel and members of the Corporate Bodies of the FRL are bound not to divulge the so-called “privileged information”, i.e. information of definite content, not available to the public, concerning activities, decisions to be taken and measures relating to proceedings underway, both inside and outside the Foundation, and such as could significantly influence any behaviour if divulged improperly or in advance of their official or formal publication or communication, thus creating positions of improper advantage.

ART. 9
Protection of the image

1. Even outside the work environment and working hours, the staff and members of the Corporate Bodies shall not engage in conduct that may prejudice the interests of the Foundation or damage its image and reputation;

2. At the national headquarters, offices and branches abroad and during missions, the staff and members of the Corporate Bodies of the Foundation shall ensure the utmost collaboration in their relations with colleagues and third parties, respecting the positions and roles they hold and inspiring their conduct to appropriate standards of behaviour compatible with the duties and functions of the office and with the protection of the image and reputation of the Foundation, avoiding attitudes and types of behaviour that may disturb the required atmosphere of peace and harmony. The staff of the Foundation, when in service abroad, must especially inspire their conduct both in private and in office and in public to the most rigorous principles of discipline, honour, correctness and decorum imposed by the greater burdens deriving from the representative functions of their own and of the office of which they are part and by respect for the laws and local customs;

3. Personnel and members of the Foundation’s Corporate Bodies shall refrain from making public by any means, including the web or social networks, blogs or forums, comments, information and/or photos/videos/audio that may damage the image and reputation of the Foundation, the honour of colleagues, as well as the confidentiality or dignity of persons. When using one’s personal profile on social media, if one’s affiliation with the FRL can be deduced from the user’s profile or detected by the content of a post, it is always necessary to specify that the messages posted reflect personal opinions and not the views of the Foundation. Particular caution should be exercised by all staff serving abroad, whose communications could be more easily identified with official positions in their home country. Their user profiles should never be used for official statements or the disclosure of official information;

4. The Foundation receives reports from personnel serving abroad on cases in which the benefits and immunities granted by international regulations are denied or unduly restricted, also with a view to reporting them to the competent authorities. Personnel serving abroad, aware that the above-mentioned benefits and immunities are granted by local authorities exclusively for the best pursuit of the requirements of the service and not for personal interest or advantage, are required to use them in accordance with this purpose, avoiding any abuse. Personnel serving abroad shall not abuse or take advantage for their own personal interests of the position of prestige that they derive from performing functions connected with institutional relations.

ART. 10
Staff relations

1. The Foundation uses its own staff to carry out its work and institutional tasks, in Italy and abroad;

2. The assessment of the staff to be recruited is carried out on the basis of the correspondence of the candidates’ profiles with those expected and with the requirements of the Foundation, in compliance with equal opportunities and Articles 5 and 6 of this Code, for all those concerned;

3. In compliance with the provisions of Articles 5 and 6 of this Code of Ethics, current or retired personnel who are called upon to carry out an activity outside the Foundation undertake not to divulge information they have become aware of in the performance of their duties;

4. Personnel and members of the Social Bodies of the Foundation who wish to report acts of harassment, abuse, sexual exploitation and mobbing, whether suffered personally or by other members of the personnel and Social Bodies of the FRL, may contact, even anonymously, by e-mail and/or regular mail and/or telephone the Secretary General of the FRL. If it is not possible to contact the Secretary General, the staff and members of the Corporate Bodies of the FRL may make the report directly to the President of the Foundation. The Secretary-General and/or the President shall inform the Board of Directors of the FRL of the report, which shall decide collectively on the measures to be adopted in the case in question.

ART. 11
Relations with the public

1. The staff and the members of the Foundation’s Corporate Bodies shall establish a relationship based on fairness and courtesy with all the subjects that come into contact with the FRL, whether they are Italian citizens or foreigners, that also adequately takes into account cultural differences so as to avoid behaviour that could be interpreted as intolerant or discriminatory; the persons who come into contact with the FRL are adequately informed of the administrative procedures to be followed and each of their requests deserves equal consideration and respect; the staff and members of the Corporate Bodies of the FRL fulfil them in accordance with the law, in the shortest possible time and avoiding favourable or discriminatory treatment;

2. The staff dealing with the public are required to wear in a legible manner an identification badge made available by the FRL, unless otherwise stipulated by the service, also in consideration of the safety of the staff themselves or safety issues in the field.

ART. 12
Special provisions for management staff

1. Management staff shall diligently perform the duties incumbent on them according to the deed of appointment, pursue the objectives assigned to them and adopt an organisational behaviour appropriate to the performance of their duties;

2. Before taking up her/his duties, the managerial staff shall inform the Chairman of the Foundation of any shareholdings and other financial interests that may place her/him in conflict of interest, even potential or apparent, with the function he/she performs. Before taking office, s/he must also declare whether s/he has any relatives and relatives-in-law up to the second degree of kinship, spouse or cohabitants who engage in political, professional or economic activities that place them in frequent contact with the FRL or who are involved in decisions or activities pertaining to it. The aforementioned notifications shall be submitted by means of self-certification made pursuant to Presidential Decree no. 445 of 28 December 2000 - to be transmitted by email - and shall commit the management staff to inform the Foundation of any changes by email within 10 days of their occurrence;

3. The managerial staff shall adopt loyal and transparent attitudes and behave in an exemplary and impartial manner in relations with colleagues, collaborators and recipients of action. The managerial staff shall also ensure that the resources allocated to their sector are used exclusively for institutional purposes and, under no circumstances, for personal needs;

4. Depending on the resources available, the managerial staff shall take care of the organisational wellbeing in the structure they are in charge of, favouring the establishment of friendly and respectful relations among the co-workers, undertake initiatives aimed at the circulation of information, at the training and continuous training of the staff, at the inclusion and promotion of differences in gender, age and personal conditions;

5. The managerial staff shall assign the preliminary study of cases on the basis of a fair distribution of the workload, considering the skills, aptitudes and professionalism of the staff at its disposal. The managerial staff shall assign additional tasks on the basis of professional skills and, as far as possible, according to principles of rotation;

6. The managerial staff shall carry out the assessment of the staff assigned to the structure they are in charge of with impartiality, and observing the prescribed indications and time limits;

7. The managerial staff, should they become aware of an irregularity, shall promptly undertake the consequent and necessary initiatives; they shall promptly activate and report the violation to the President and to the Control Body of the Foundation itself; they shall lend, when requested, their collaboration and promptly forward a report to the criminal judicial authorities for their respective competences, informing the President and the Control Body of the Foundation beforehand. In the event of receiving a report of wrongdoing from staff and/or members of the Foundation’s Corporate Bodies, s/he shall take every legal measure to ensure that the reporting party is protected and that her/his identity is not unduly revealed in the disciplinary proceedings, pursuant to the provisions of the current legislation on the subject (Law no. 179 of 30 November 2017, so-called whistleblowing);

8. The management staff, within the limits of its possibilities, shall prevent the spreading of untrue news relating to the Foundation and the activities of the Foundation, as well as of the staff and members of the Corporate Bodies of the Foundation. They shall promote the dissemination of knowledge of good practices and good examples in order to strengthen the sense of trust in the Foundation.

ART. 13
Special Provisions for Foundation Staff Abroad

1. The Foundation’s management staff abroad

• is responsible for creating the conditions for a smooth working environment based on mutual respect and motivation of colleagues. It fosters, within the limits of available resources, the conditions for an organised and careful activity, in order to ensure the well-being of the staff and their better integration into the working and cultural environment;

• ensures that measures for the physical safety of staff are implemented;

• coordinates measures for the physical safety of staff;

• monitors compliance with the benefits and privileges provided;

• reports any discriminatory attitudes on the part of the accreditation authorities towards staff;

• pays special attention to compliance with the provisions of the law and of this Code regarding conflicts of interest, incompatibility, multiple job holding, as well as the provisions for preventing and combating bullying.

ART. 14
Codes of Conduct for Civil Society Organisations (CSOs) and other non-profit entities that are partners of FRL initiatives

1. The CSOs and other non-profit entities that are partners in the implementation of the FRL initiatives are invited by the Foundation to adopt a code of ethics and conduct consistent with this code.

ART. 15
Supplementary budget resources (sponsorship and donations)

1. In order to guarantee a better quality of its services in the national headquarters, in the branches and offices abroad and during the missions, the Foundation may resort to supplementary budget resources: in particular sponsorships, services provided to users and free donations;

2. Advertising is forbidden if it is detrimental to the Foundation’s image and it is of a political, trade union, sectarian or religious nature, with obscene, offensive, fanatical or racist messages, or whose content contravenes binding regulations, if it is likely to cause a conflict of interest between the public activity of the staff and members of the Foundation’s governing bodies and their private sphere, or is contrary to general appropriateness, also taking into account the customs and traditions of the country of accreditation;

3. The Foundation shall ensure that the nature of the subject granting donations and sponsorships, as well as the activities it carries out directly or through controlled entities, are not in conflict with its mission or detrimental to the dignity of persons and the environment. Particular care will be taken to ensure that the activities being sponsored are consistent with the functions and dignity of the Foundation’s mission.

ART. 16
Respect for the environment and eco-sustainability

1. The Foundation shall, subject to budgetary resources, ensure an environmentally friendly organisation of work and services, in particular by promoting energy saving, dematerialisation of documents and recycling of renewable materials;

2. The Foundation is committed, both at central and peripheral level, to promoting high environmental standards. In particular, the Foundation complies with the prescriptions of the local authorities in the areas in which it operates, in terms of environmental protection, waste production and disposal, and pollution, respecting and implementing all applicable laws and regulations. It directs the purchase of goods towards products that ensure the environmental sustainability of the production process;

3. FRL personnel and members of the Corporate Bodies are obliged to maintain the functionality and decorum of the working environments, as well as to use objects, equipment and tools exclusively for work purposes and to adopt a behaviour aimed at reducing waste and saving energy.

ART. 17
Contributions and sponsorships

1. Contributions, grants, credits, subsidies and benefits of an economic nature, whether granted or received, shall be publicised in their entirety in the “Budgets” section of the Foundation’s website;

2. The Foundation may grant its patronage or declare its willingness to participate in the organisation of initiatives or events relating to the fields of activity set out in Article 1 paragraph 1 of this code;

3. In order to qualify for the recognition referred to in paragraph 2 of this article, initiatives must be of clear and appreciable relevance and have a significant and documented effect.

ART. 18
Accountability for violating the duties of this Code

1. Without prejudice to any civil, administrative, accounting and criminal liability governed by the law, the breach of the provisions of this code constitutes a case of disciplinary liability to which the provisions of the current laws and collective bargaining agreements apply for the various categories of personnel covered by the code. As a general rule, and without prejudice to the assessment of individual cases, breaches of the provisions of this code correspond to offences under the disciplinary measures laid down by law and by collective bargaining for each category of staff of the Foundation;

2. The provisions of law and of national collective bargaining concerning recidivism and mitigating or aggravating circumstances remain unaffected;

3. This is without prejudice, in any case, to the possibility of dismissal in the cases provided for by law, regulations and collective bargaining agreements;

4. For the persons referred to in Article 2, paragraphs 1 and 2 of this code, the liability resulting from violations of the code is governed by their respective contracts, assignments, collaboration, consultancy or any other type of relationship stipulated with the Foundation.

ART. 19
Notification

1. This code is publicised by its permanent publication on the Foundation’s website (https://unraggiodiluce.org/), as well as by any other means useful for sharing it with its cooperation project partners and the local communities;

2. Contextually with the signing of the employment contract or, in the absence of the latter, with the act of conferment of the assignment, or any other act suitable for establishing the collaboration relationship between FRL and the parties referred to in Article 2 of this code, a copy of this code shall be submitted for signature.

ART. 20
Final Provisions

1. This code shall be adopted by the Foundation’s Board of Directors, on the proposal of the President of the FRL, by means of a procedure open to participation and after hearing the opinion of the Secretary-General of the FRL;

2. Once the procedures referred to in the first paragraph of this Article have been completed, the final text of this Code shall enter into force on the day following its publication on the Foundation’s website;

3. This code is valid for an unlimited period of time. Any amendments will be adopted through the procedure identified in the first paragraph of this Article and made public through the procedure identified in the second paragraph of this Article.

Pistoia, 22.02.2024