Code of Conduct | We4 Clinical Research

PREMISE

We4 Clinical Research, with the aim of promoting actions designed to protect the dignity and inviolability of individuals and to ensure equal treatment between men and women in the performance of any activity involving company personnel, in Italy and abroad, adopts this Code of Conduct by referring to:

The constitutionally enshrined principles of equality between men and women, protecting individuals and workers;
European Union legislation on the protection of the dignity of women and men in the workplace and on sexual harassment;
The applicable national legislation in force;
The applicable collective bargaining agreements.

With this Code, We4 Clinical Research intends to equip itself with a tool aimed at preventing and/or countering behaviours that constitute violence and harassment against shareholders, employees, and third parties involved in corporate activities.

PRINCIPLES AND PURPOSES

The Code aims to implement a policy to prevent violence and harassment in the workplace and guarantees employees, shareholders, or collaborators, should such events occur, immediate and simple access to appropriate procedures to address the issue and prevent such situations from recurring.

With this Code, the intention is to encourage the development and implementation of policies and practices designed to create a working environment free from violence and blackmail and a corporate climate in which men and women mutually respect the dignity and inviolability of one another.

We4 Clinical Research rejects violence of any kind and form, harassment, bullying, and mobbing, and constantly endeavours to strengthen its responsibility to address and manage reports in a responsible and transparent manner.

We4 Clinical Research ensures moral consistency and respect for human values inside and outside the Company, protects dignity, gender equality, diversity, and inclusion, as well as compliance with the applicable labour law.

We4 Clinical Research also promotes a synergistic relationship and mutual respect between management and employees.

We4 Clinical Research believes that its employees and collaborators have the right to be treated in accordance with the principles of equality and equal treatment and to be protected by the Company from any interference or aggression of which they may be victims because of their role.

All individuals belonging to We4 Clinical Research are entitled to a safe, calm, and favourable organizational and corporate climate for the development of interpersonal relationships in which women and men mutually respect the dignity and rights of individuals, guiding their behaviour by values of equality and fairness.

Each person belonging to We4 Clinical Research, whether shareholder, employee, or collaborator, must maintain conduct that is correct and worthy of the Company to which they belong, such as to maintain and increase the community’s trust in the Company, offering the best possible service while respecting the dignity of employees and the beneficiaries of We4 Clinical Research’s activities.

Any discriminatory or offensive behaviour that constitutes violence and/or harassment represents an intolerable violation of the freedom and dignity of the individual and may compromise their physical and psychological integrity, trust, morale, and motivation at work, negatively impacting the corporate climate, work performance, and the image of We4 Clinical Research.

All shareholders and employees have a duty to cooperate inside and outside the Company to ensure the achievement of these purposes.

Any violation of this Code constitutes a disciplinary offence.

A person who is a victim of violence and/or harassment has the right to obtain the cessation of the harassing behaviour and the removal of its consequences, including through access to procedures appropriate for this purpose.

This Code is intended to:

Inform and raise awareness among personnel belonging to We4 Clinical Research, shareholders, employees, and collaborators about their rights and obligations regarding the prevention and removal of the above-mentioned behaviours;
Encourage reporting in good faith, including anonymously, of abuse, discrimination, violence, or harassment, or in any case behaviour not in line with the principles of this Code, whether suffered directly or otherwise known, ensuring the protection of the whistleblower from possible retaliation, the prompt handling of every report, and guaranteeing confidentiality;
Provide information on the procedures in force for the management of complaints of violence and harassment, as well as on the protection and redress mechanisms available at company level, without prejudice to any other form of legal protection.

DEFINITIONS AND RULES OF CONDUCT

Under the Equal Opportunities Code (Articles 25 and 26 on Equal Opportunities at Work), harassment is also considered discrimination and is defined as “any unwanted conduct related to sex, which has the purpose or effect of violating the dignity of a female or male worker and of creating an intimidating, hostile, degrading, humiliating or offensive environment.”

Sexual harassment is an act of discrimination under Article 26, paragraphs 1 and 2 of Legislative Decree 11 April 2006, no. 198, and consists of any behaviour of a sexual nature, expressed in physical, verbal, or non-verbal form, which is unwanted and which has the purpose or effect of violating the dignity and freedom of the person who suffers it and of creating an intimidating, hostile, degrading, humiliating, or offensive environment.

Sexual harassment also includes sexual abuse, which refers to any actual or threatened physical or psychological intrusion of a sexual nature, carried out either through the use of force or by exploiting conditions of imbalance and coercion affecting the beneficiaries, and sexual exploitation, which consists in any actual or threatened abuse of conditions of vulnerability, power imbalance, or trust for sexual purposes towards beneficiaries.

Sexual harassment is also deemed to exist where the perpetrator’s behaviour is not accompanied by blackmail or threats, but is nevertheless offensive and unwanted by the person who suffers it. Even a single isolated act, if not repeated, may constitute sexual harassment.

By way of example and without limitation, the following are deemed to be sexual harassment:
a) Explicit or implicit references or innuendos of a sexual nature, which are offensive or disturb the recipient’s peace of mind;
b) Intentional use of unwanted, improper, or inappropriate physical contact and/or allusive and provocative gestures;
c) Intentional and explicit use of phrases or written communications of a sexual nature that are unwanted and offensive, inappropriate, offensive, or otherwise unwanted comments about someone’s physical appearance;
d) Use of gestures and behaviours with clear sexual connotations, including non-verbal, which harm the dignity of the recipient;
e) Requests for sexual favours in exchange for promises of professional or economic advantages;
f) Threats, blackmail, and retaliation suffered for having rejected sexually oriented behaviours, affecting, directly or indirectly, the establishment of the employment relationship, its performance, career progression, termination of employment, training, and corporate activities.

For the purposes of this Code, sexual harassment perpetrated against shareholders, employees, or any collaborator, on the grounds of sex or sexual orientation, ethnic origin, religion, personal or political beliefs, disability, or age, or involving human traffickers and victims of trafficking for the purpose of sexual exploitation, is considered aggravated discrimination.

Furthermore, repeated sexual harassment and sexual harassment perpetrated by a hierarchical superior are deemed aggravated discrimination for the purposes of this Code.

By way of example, at We4 Clinical Research, the following conduct is prohibited, which does not exhaust all cases in which behaviours prohibited by this Code may materialise:

Committing acts of sexual abuse or sexual exploitation;
Committing acts of physical and/or verbal violence;
Engaging in sexual acts with persons under the age of 18 (regardless of the age of majority in the country where they operate) or with non-consenting adults;
Offering money, employment opportunities or career progression, goods, or services in order to obtain sexual favours or to engage in other forms of humiliating, degrading behaviour or sexual exploitation (this prohibition applies regardless of the applicable legislation on prostitution);
Producing, procuring, distributing, or using pornographic material on company premises or with company equipment and resources, as well as viewing pornographic material or browsing pornographic websites or forums, or sending and receiving emails with pornographic content.

SCOPE OF APPLICATION

The recipients of this Code are shareholders, employees, collaborators, and in general anyone operating on behalf of We4 Clinical Research.

The Code applies in the event of violence and harassment, whether reported or otherwise known, in the workplace or in the performance of any activity involving personnel belonging to We4 Clinical Research, in Italy and abroad, in any capacity and regardless of the type of relationship established and the role held within the Company.

IMPLEMENTATION OF THE PREVENTION POLICY

The policy to prevent violence and harassment must be implemented at all levels of We4 Clinical Research, both with respect to shareholders and employees.

We4 Clinical Research personnel, at all levels:

Have a duty to promote the prevention of abuse and harassment in the workplace and in places where corporate activities are carried out and to implement a policy based on the protection of dignity and equal opportunities;
Are required to ensure compliance with this Code and promote the dissemination of the principles contained in it;
In the event of behaviour that constitutes violence and/or harassment under this Code, are obliged to take the measures deemed most appropriate from an organizational and managerial point of view to protect the persons involved, paying particular attention to restoring an environment conducive to proper interpersonal relationships, protecting the whistleblower from possible retaliation, and protecting the confidentiality of all persons involved;
From a disciplinary perspective, are also obliged to promptly forward the report for assessment of its disciplinary relevance by the competent bodies.

MANAGEMENT OF REPORTS OF VIOLATIONS OF THE CODE OF CONDUCT

Without prejudice to the right to bring the matter before the Judicial Authorities, if behaviour occurs that may constitute violence and/or harassment in the workplace or in places and in the performance of any activity involving personnel belonging to We4 Clinical Research, the person who believes they have been subjected to violence and/or harassment may promptly report the incident, formally or anonymously via the company whistleblowing system, to Management, which will initiate appropriate investigations in order to assess the possible disciplinary relevance of the reported conduct, without prejudice to any other form of legal protection they may avail themselves of.

Management shall initiate the necessary investigations and, once the existence of behaviour that may constitute violence and/or sexual harassment has been assessed, shall take all initiatives deemed appropriate to immediately stop the harassing behaviour, safeguarding the primary interest in the dignity of shareholders, employees, and third parties involved in the matter and guaranteeing their confidentiality.

If sufficient evidence emerges from the preliminary investigation phase, it shall initiate disciplinary proceedings, which are governed by the applicable national collective labour agreement.

Pending completion of the disciplinary proceedings, at the request of one or both of the parties concerned, Management may adopt a temporary measure (assessed on a case-by-case basis) in order to restore a peaceful climate.

Internal investigations prompted by a possible report of abuse or harassment must be conducted with the necessary sensitivity and in compliance with the rights of both the alleged victim and the alleged harasser.

The procedure must be completed within the time limits provided for the disciplinary proceedings initiated and records must be kept of the actions taken, the meetings and investigations carried out, the persons interviewed, and the solutions identified in response to the report.

Management, once the validity of the report has been established, shall ensure that the person who submitted it is protected from any form of retaliation and shall monitor the actual cessation of the harassing behaviour. Every case of retaliation may be assessed from a disciplinary standpoint.

Management shall consider any disciplinary action against individuals who report cases of violence and/or harassment in bad faith, and shall adopt appropriate initiatives to protect the person who has been falsely accused.

Shareholders and employees found to have committed sexual harassment shall be subject to the disciplinary measures provided for by the applicable legal, contractual, and regulatory provisions.

Behaviours that constitute sexual harassment, as described in Article 3, have disciplinary relevance (without prejudice to any civil or criminal relevance of the conduct) and are punishable in accordance with the procedures and methods set out in the applicable national collective labour agreement, to which reference is made for all matters not expressly governed by this Code.

DISCLOSURE OBLIGATIONS

During the annual Management Review, Management and the Steering Committee prepare a report indicating the disciplinary proceedings initiated in relation to incidents of violence and/or harassment concluded during the year and any sanctions imposed, in compliance with legislation on confidentiality and data protection.

This report will make it possible to monitor the state of implementation of the policy for the prevention and contrast of violence and harassment and to assess the need for its improvement.

CONFIDENTIALITY AND DATA PROTECTION

All We4 Clinical Research personnel who become aware, in any capacity, of reports or of the handling of cases of violence and/or harassment are required to maintain the strictest confidentiality regarding personal data and the information and news acquired in this regard.

The above-mentioned persons undertake to adopt every appropriate security measure to prevent unauthorized third parties from becoming aware of the information processed.

The same persons also undertake to limit the use of personal and identifying data so as to exclude their processing when not necessary.