231 Model and Code of Ethics

ESHQ Consulting implemented a Model of Organization, Management and Control, according to the italian law which regulates Corporate Social Responsibility regarding crimes performed by its employees. The implementation of this system is also to be intended as an act of responsibility towards its employees, partners, customers and suppliers.

This initiative was taken in the belief that the implementation of the model could be a valid instrument to all those who operate in the name and on behalf of the Company, both to give a moral guideline an to prevent the risk of the crimes specified in the beforementioned law.

Although the adoption of the Model is optional and not mandatory, ESHQ Consulting sought, however, to proceed to its realization and adoption.

The Company also intends to observe high ethical standards in the daily operation of their work: such standards, and their principles, are collected in the Code of Ethics, which has been adopted in conjunction with the Company’s Model of Organization.

The Code applies in relation to all the activities carried out in the name and on behalf of ESHQ Consulting, both in Italy and abroad, taking into account the cultural, social and economic integration of the countries in which the Company operates.

It is possible to ask for our Company’s Model of Organization by writing to: odv@eshqconsulting.it

Writing to: odv@eshqconsulting.it

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