Governance and Code of Ethics
We believe that every solid company needs a Code of Ethics and a Governance Model, to ensure that the company development is in perfect harmony with the company‘s managerial, technical and commercial growth.
The Governance Model, drafted in accordance with Confindustria guidelines, sets the rules which apply to all entities (individuals and legal entities) in connection with Proge.
The Model translates, into organizational rules, the principles and moral values prescribed by the Code of Ethics.
The Code of Ethics defines, with clearness and transparency, the system of values and ethical principles to which the company is inspired in achieving its business goals. It is a commitment of the entire business organization and any person related to the company itself to comply with the provisions of law, labor contracts and company regulations relating to ethics and legality.
The General Section and the Code of Ethics are released to the public with this publication.
Governance Model - General Section
Code of Ethics
Integrated Policy Statement of the Company Management System
Whistleblowing
In line with best practices and with national regulations on whistleblowing (Legislative Decree no. 24 of March 10, 2023, as amended, the “Whistleblowing Decree”, and Legislative Decree no. 231 of June 8, 2001, as amended), Proge-Software has implemented an appropriate system for collecting and managing reports, ensuring the confidentiality of the whistleblower and the content of the reports, as well as the legal protections provided.
The procedure for submitting reports is detailed in our Governance Model – General Section.
Providing personal data is optional. Any data submitted will be processed for the duration of the handling of the report and retained for the time necessary to process it, and in any case no longer than five years from the date on which the final outcome of the reporting procedure is communicated, in compliance with the confidentiality obligations set out in Article 12 of Legislative Decree 24/2023 and the principles set out in Article 5(1)(e) of Regulation (EU) 2016/679 and Article 3(1)(e) of Legislative Decree No. 51/2018.
The data will be processed solely by personnel authorized by the Data Controller and by entities expressly appointed as Data Processors, exclusively for technological maintenance needs of the platform. The data will not be disclosed to third parties nor disseminated, except in cases expressly provided for by national or EU law.