ATWC has identified its own ethical principles of reference that make up the driver of its activities.

The ethical principles listed below represent the core values that all Recipients must adhere to in the conduct of activities and in the pursuit of the company's mission.

Under no circumstances does the belief to act for ATWC's benefit justify behavior contrary to the principles of this Code.

Respect for the dignity of the person

ATWC considers respect for the human person to be a priority. Behaviors that have discriminatory content based on political and union views based on political and union views, religion, race, nationality, age, gender, sexual orientation, health status and, generally, any characteristic of the Staff. ATWC works to ensure that the rights provided by the "Universal Declaration of Human Rights" are guaranteed in the various places where it operates.

Observance of the law

ATWC has as an essential principle compliance with the laws, regulations, uses and, in any case, all the regulatory provisions in Italy and in all countries where ATWC should operate.


Recipients must be aware of the ethical significance of their actions and should not pursue personal or business gain in violation of applicable laws or in violation of this Code.

Fairness in business transactions

All trade negotiations must be fair. No commercial or market logic can justify untruthful information as a tool for the pursuit of self-interest or ATWC. In correspondence, negotiations, in the formulation of contractual agreements, ATWC undertakes to show its will or

statements clearly and understandably to the recipient.

All shares of ATWC and relations with its shareholders and/or other interest-bearing parties must be carried out ensuring fairness, completeness, uniformity and timeliness of information.


ATWC does not approve or justify any action of violence or threat to obtain conduct contrary to applicable law and/or code of ethics.

Proper accounting management

ATWC is aware of the importance of transparency, accuracy and completeness of accounting information and works to have a reliable administrative-accounting system in correctly representing

management facts and in providing the tools to identify, prevent and manage, as far as possible, financial and operational risks, as well as

fraud against ATWC. In accordance with the principle of transparency, every transaction and transaction must be properly recorded, authorised, verifiable, legitimate, consistent and consistent.

Accounting records and documents must be based on accurate, comprehensive information, and must reflect the nature of the transaction referred to in accordance with external constraints (law standards, accounting principles), as well as policies, policies, internal plans, regulations and procedures; In addition, they must be accompanied by the relevant supporting documentation necessary to enable objective analysis and verification. Both internal and external reviewers must have free access to the data, documents and information needed to carry out their work. Each Recipient must operate in a way that prevents any form of accounting wrongdoing, immediately reporting any anomalies to the


Loyalty in competition relations For ATWC, it is crucial that the market is based on fair and fair competition.

Recipients therefore undertake to scrupulously comply with and observe all laws regarding the protection of competition and the market in any jurisdiction and to cooperate with the market regulators.

No Recipient may be involved in initiatives or contracts with competitors, which may appear to be breaches of competition and market regulations.

In particular, recipients are obliged to:

  do not put in place any conduct that would disturb the freedom of industry and commerce;

  Do not use violence or threat in order to disrupt or prevent the exercise of a competing activity;

  do not use fraudulent means to influence the free market;

  do not put in place any deceptive or disparaging conduct in order to disturb the free conviction of the consumer.

Environmental protection and sustainable development

Environmental protection is the subject of the utmost care

PART of ATWC. ATWC is aware that the environment is a primary asset; Sustainable development is one of the founding principles of this Code.

As a result, ATWC is committed to implementing all cost-effective actions for environmental care, improving the quality of the eco-system and preventing environmentally harmful effects whenever possible.

The same commitment relates to the protection of human health in its relationship with the environment.

ATWC promotes an environmental culture, supporting its activities with scientific research oriented in an environmental sense, always keeping in mind the right balance between economic needs and essential environmental needs.

The choice of technologies, development programmes, and

business strategies will put environmental protection at the top of the agenda.

Responsibility for the community

ATWC works taking into account the needs of the communities in which it carries out its activity, contributing, where possible, to their economic, social and civil development.


In any work activity, the cost-effectiveness of the management and use of company resources must be pursued, in accordance with the most advanced quality standards.

ATWC also:

  to safeguard and safeguard company resources and assets, as well as to manage their assets and capital by taking all necessary precautions to ensure full compliance with existing laws and regulations; 

  to ensure an ongoing dialogue with the German parent company ATWC SE, in accordance with the procedures adopted for communication outside the documents and price sensitive information.

Spirit of service

ATWC takes all necessary steps to ensure that Recipients direct their conduct, within the limits of their respective competences and responsibilities, to the pursuit of the company's mission to provide a service of high social value and usefulness for the should benefit from the best quality standards.

Quality of reports

In the context of relationships with suppliers, customers and every third party, ATWC operates with transparency, fairness and honesty. 

Personnel management

Human resources relations

ATWC recognizes the value of human resources as a fundamental and essential factor for atWC's business development and growth.

With a focus on the moral and physical integrity of staff, ATWC promotes a pleasant, stimulating and rewarding work environment and ensures respect for the autonomy of resources

and the importance of their participation in the pursuit of the company's mission.

ATWC reiterates its commitment to comply with child labour laws, as well as to combat any kind of discrimination in the workplace due to gender, nationality, religion, political, union and personal views, economic conditions.

Staff who believe they have been discriminated against may report the incident to the relevant corporate bodies or functions, who will proceed to verify the actual violation of the Code of Ethics.

Privacy protection

The acquisition, processing and retention of personal information and data takes place in accordance with specific procedures to prevent unauthorized persons and/or entities from learning about it. These procedures comply with applicable regulations, in particular ATWC ensures compliance with the provisions of EU Regulation 679 and subsequent changes and additions.

Customer relationships

Impartiality and quality of information to customers

ATWC, in providing customers with products and services,

is committed to acting with fairness and transparency, in accordance with applicable laws and regulations,     and meet their needs by fulfilling their contractual obligations. ATWC disavows any principle of discrimination based on gender, nationality, religion, personal and political opinions, the age and economic conditions of its interlocutors. For these purposes too, the quality of service provided will be monitored periodically.

Transparency to customers

With regard to the contracts and communications with customers, ATWC is committed to using clear and simple terms, in order to facilitate the

Recipients, as well as clauses in accordance with applicable regulations and the guidance of the Public Authorities.

Customer relationships

In order to ensure a proper and positive relationship with its customers, ATWC is committed to the management and timely resolution, where possible, of any complaints, using appropriate communication systems.

ATWC will do:

  in order to limit any legal disputes with clients, committing to use them only where their legitimate claims do not find the right fulcilable satisfaction; 

  in order to protect the privacy of its customers, in full compliance with the current rules regarding the communication and dissemination of personal data.

Vendor selection

ATWC is committed to identifying its suppliers in order to ensure equal treatment and impartiality.

ATWC uses objective and transparent criteria for choosing suppliers. This choice, in accordance with existing rules and internal procedures, must be made on the basis of objective assessments of the competitiveness, quality and economic conditions applied.

There are special procedures for documenting the overall selection and purchasing process, with the aim of ensuring maximum transparency of the evaluation and choice of the supplier.

The supplier will also be selected in view of the ability to guarantee:

  compliance with this Code of Ethics;

  implementation of appropriate business quality systems, where provided;

  the availability of suitable means and organisational structures;

  compliance with labour laws, including child labour, health and worker safety.

In any case, ATWC undertakes not to establish any commercial relationship with individuals, whether individuals or legal entities, involved in acts of terrorism or who are otherwise unable to ensure the absolute legitimacy of their work and the accordance with the ethical principles of reference outlined in this Code 

Transparency and fairness in contract execution

ATWC is committed to maintaining a strict separation of roles between those who make purchase requests and those who are members of the contract and management


To this end, there are special procedures for documenting the overall selection and purchasing process, with the aim of ensuring maximum transparency of the evaluation and choice operations.


ATWC, together with its suppliers, works to establish a collaborative and mutually satisfying relationship. This relationship must be based on the estimation and trust between the parties. In this regard, the supplier must

be timely and thoroughly informed about the characteristics of the activity, the forms and

payment times, in accordance with the current rules and the expectations of the other party, given the circumstances, negotiations and content of the contract. Similarly, the supplier must fulfil its contractual obligations in accordance with the principles of fairness, fairness, diligence and good faith, as well as in accordance with the current legislation and this Code.

In any case, with regard to payment

ATWC complies with contractual terms and is committed to ensuring equality between suppliers.

Protecting individual personality

ATWC recognises the need to protect individual and personal freedom and repudiates any act that promotes phenomena such as prostitution and/or pornography with particular reference to juvenile pornography, including through the unlawful use of systems company's IT companies.

Protection of occupational health and safety

ATWC ensures compliance with workplace health and safety regulations. ATWC counters the risks associated with carrying out its business by assigning the assignments in line with the subject's competence and is committed to preventing Employees from having to do monotonous and/or repetitive work.

In terms of occupational health and safety, ATWC is also committed to:

(a)  taking into account the degree of evolution of the technique;

b)  replacing what is dangerous with what is not dangerous or less dangerous;

c)   adequately planning prevention and aiming for a coherent complex that takes into account and integrates the organization of work,

working conditions, social relations and the influence of factors in the working environment;

d)  prioritising collective protection measures over individual protection measures;

(e)  giving proper instructions to the staff.

These principles are used by ATWC to identify and take the necessary measures to protect the safety and health of workers, including occupational risk prevention activities, information and training, as well as organization and the necessary means. Protection of transparency in business transactions and tax and tax transactions (anti-money laundering and self-recycling)

ATWC has as its principle that of maximum transparency in commercial transactions and prepares the most appropriate tools in order to counter the phenomena of recycling and receiving. ATWC guarantees the correctness of every tax transaction and tax compliance. The principles of fairness, transparency and good faith must be guaranteed in dealings with all contractual counterparts, even if they are part of the same ATWC Group.

Standards of conduct for staff

Staff must comply with the current regulations as well as the principles identified by the Model and the Code of Ethics.

With regard to the Model, the Staff must:

(a)  avoid putting in place, causing cause or

to cooperate in the implementation of conduct suitable to integrate any of the offences referred to in the Decree;

b)  collaborate with the Certificationing Board (below)

'OdC' or 'Organism') during the verification and supervision activities carried out by these, providing

the information, data and news requested by it;

c)   communicates under the Model to the ODC;

d)  report any malfunctions or violations of the Model and/or Code of Ethics to the OdC.

Proper use of computer systems and copyright protection

ATWC guarantees compliance with copyright infringement regulations and uses only licensed computer programs, avoiding unlawful duplication.

To this end, the Recipients are committed to ensuring that no wrongdoing is put in place that may

violate copyright legislation. The staff, within the limits of their functions and duties,

It is responsible for the security of the computer systems used and is required to comply with applicable regulations and the terms of the licensing agreements.

For this purpose, staff are prohibited from uploading borrowed or unauthorised software to company systems, as well as unauthorised copies of programs, licensed, for personal, business or third-party use.

Except under civil and criminal laws, staff are also required not to send messages, e-mails, and abusive messages, not to use language expressions that do not conform to the style, of ATWC, or at least a low-level language 

Similarly, information traffic within the company's telematics network should not be activated to significantly reduce its efficiency with negative impacts on relational capacity.

ATWC.  You will not be able to browse sites

Internet with indecorous and offensive content,

you will have to take scrupulously as required by the company's security policies, in order not to compromise the functionality and protection

information systems.

Staff are prohibited from accessing, downloading images or files from sites containing pornographic and/or child pornography.

Staff are required to make the necessary commitment in order to prevent the possible commission of crimes through the use of computer systems.

Control of the Code of Ethics. Monitoring mode

The implementation and compliance of the Code of Ethics must be continuously monitored by the

Supervisory Authority, which, in particular, must:

  check that the Recipients comply with the Code of Ethics;

  comment on the matter

ethical issues that arise in business decisions;

  provide stakeholders who request clarifications and clarifications regarding the interpretation of the Code or legitimacy

behavior of one's own or other;

  stimulate and coordinate the upgrade

Code of Ethics, including through its own proposals for adjustment or updating;

  promote and monitor the development of communication and training activities on the Model and,

In particular, on the Code of Ethics, determined by ATWC.

Violations of the Code of Ethics and related penalties

With regard to the tying of violations of the Code of Ethics, a special Disciplinary System has been prepared, approved together with the Reporting of violations of the Code of Ethics If a subject complied with the Model and this Code Ethical to be aware of a fact that is right to believe constitutes a violation, even potential, of the same must report it in a timely manner to the ODC. in which to send any reports regarding non-compliance with the Model or this Code, which will also be used for the receipt of anonymous reports, i.e. those in which it is not possible to trace the identity of the sender;

In any case, the ODC works to ensure that those who have made the reports are not subject to retaliation, discrimination or, in any case, penalties, thus ensuring the appropriate confidentiality of those entities.