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Code of Ethics


Frigerio Viaggi S.r.l. (hereafter also the "Company"), was founded in 1983 and operates in the tourism and ancillary services sector.

Frigerio Viaggi S.r.l. also in order to make the ethical and social principles of which it recognizes the importance effectively in force within its company, has prepared this Code of Ethics aimed at the identification, in a clear and unambiguous manner, of the values of justice, honesty, fairness, attention and respect to which the company has always standardized its activities.

The Company, therefore, in addition to making a direct commitment to ensure that all the principles, values and rules of this Code of Ethics find the widest possible dissemination both internally and externally, requires its employees and all those who interact or are in any way involved with it in the exercise of the business, compliance with the corporate rules and principles enshrined in this Code, believing that this is essential for the proper functioning, reputation and image of the Company as well as for the very continuation of the relationship with the individual concerned, necessarily marked by trust and reliability.


Capitalized terms used in this document have the meanings ascribed to them below:

  • Decree": means Legislative Decree No. 231 of June 8, 2001, as subsequently amended and supplemented;
  • Code” or “Code of Ethics": means this Code, as amended from time to time;
  • Target audience": indicates the persons required to comply with the provisions of this Code, including, in particular, Employees, Managers, Collaborators, Company Representatives, as well as all those who work with Frigerio Viaggi S.r.l. on the basis of a contractual relationship, including a temporary one;
  • Employees": means those persons who have an employment relationship with Frigerio Viaggi S.r.l. (including temporary or part-time workers), or any relationship assimilated thereto;
  • Responsible": means each person in charge of one or more functions of Frigerio Viaggi S.r.l., in accordance with the corporate organization chart in force from time to time;
  • Collaborators": indicates the persons who have agency, representation or commercial intermediation relationships with Frigerio Viaggi S.r.l., or any other self-employment relationship, even occasional, as well as any other person who acts as a representative of Frigerio Viaggi S.r.l. by virtue of mandates, proxies or even de facto;
  • Corporate Representatives": means, as from time to time in office, the sole director, or the president, vice president(s), chief executive officer and all other members of the board of directors, members of the board of statutory auditors, general managers of Frigerio Viaggi S.r.l., as well as any other person in an apical position, by which is meant any person who holds functions of representation, administration or management of the Company or of one of its organizational units with financial and functional autonomy or who exercises, even de facto, the management and control thereof;
  • Organization Model": indicates the organization, management and control model of Frigerio Viaggi S.r.l. adopted pursuant to Article 6 of the Decree;
  • Supervisory Board": means the body appointed by Frigerio Viaggi S.r.l. in accordance with the provisions of Article 6 of the Decree.



This Code applies to Corporate Officers, Managers, Employees and Collaborators of Frigerio Viaggi S.r.l., regardless of where they are working.

This Code is the supplementary document adopted by Frigerio Viaggi that expresses the principles of action within the Organizational Model, with specific reference to the conduct of a business built and organized around solid ethical-social values in a secular context.

The principles and provisions of the Code of Ethics are binding on all Recipients, without prejudice to the application of the mandatory provisions of the law.

This Code also applies to third parties with whom the Company has relationships, including temporary ones (collaboration, partnership, supply of goods or services, etc.).


Violation of this Code by Company Representatives, Managers, Employees and Collaborators constitutes, as the case may be, a disciplinary offence (punishable in accordance with applicable regulations) and/or a breach of contract, and may result in compensation for any damages resulting from such violation to the Company.

These individuals are obliged to observe the provisions of this Code both in their relations with each other (so-called internal relations) and in their relations with third parties (so-called external relations).


  • Company Representatives, within the scope of their administrative functions (and in particular in defining the Company's strategies and objectives, as well as in any decision or action relating to the management of the Company) and within the scope of their control functions, inform their conduct to the principles of this Code, both within the Company - thus strengthening cohesion and the spirit of mutual cooperation - and with third parties with whom they come into contact;
  • the Managers shall inform their conduct to the principles set forth in this Code and require compliance by Employees and Collaborators. For the purposes of this Code, each Manager supervises Employees and Collaborators subject to his or her direction, coordination or control and takes the necessary measures to prevent violations of this Code, having the obligation to:
  • Make a careful selection of its Employees and Collaborators on the basis of their personal and professional aptitudes, including for the purpose of compliance with this Code;
  • Communicate to its Employees and Collaborators, in a clear, precise and complete manner, the obligations to be fulfilled and specifically the obligation to comply with the law and this Code;
  • Communicate to its Employees and Collaborators in an unequivocal manner that any violations of this Code, in addition to being subject to disapproval, may constitute disciplinary offenses and/or breach of contract, in accordance with current regulations;
  • within the scope of the functions assigned to it, implement or promote the adoption of appropriate measures to prevent the commission of violations and prevent retaliation against its Employees or Collaborators or any other Employee or Collaborator;
  • the Employees and Collaborators inform their conduct to the principles provided for in this Code and to the communications of their Managers and Company Representatives taking into account, in particular, that the observance of this Code forms an integral part of the contractual obligations of the Employees, also pursuant to and for the effects of art. 2104 of the Civil Code.[1]

Without prejudice to the functions assigned to the Supervisory Board with respect to Company Representatives, Managers, Employees and Collaborators, the fulfillment by each of these Recipients of their respective functions and related obligations shall be carried out in accordance with the provisions of this Code, any recommendations or instructions of the Supervisory Board as well as the implementation and control procedures adopted by the Company from time to time.

Recipients are required to promptly report in writing to the Supervisory Board any news of potential or current violations of this Code of Ethics.

Anonymous reports are not allowed: Frigerio Viaggi S.r.l. ensures the adoption of all necessary measures to protect the reporters against any retaliation or act that could give rise to discrimination and/or penalization as a result of the report made.

Reports should be submitted to the Supervisory Board, Company Representatives and Managers in the manner indicated in the General Part of the Organizational Model adopted by the Company.

[1] Under Article 2104 of the Civil Code (relating to "Diligence of the employee"), "the employee must use the diligence required by the nature of the service due, the interest of the enterprise and the higher interest of national production. He or she must also observe the instructions for the performance and discipline of work given by the entrepreneur and the employees on whom he or she is hierarchically dependent.”


Frigerio Viaggi S.r.l. promotes the application of this Code by third parties with whom it has relations, both in Italy and abroad, including through the insertion, in the respective contracts, of special clauses that establish the obligation of such third parties to observe, within the context of relations with the Company, the provisions of this Code, with the specification that the violation of these rules may result in the legal termination of the existing contractual relationship, as well as the full right of the Company to request and obtain compensation for any damages suffered.

The Supervisory Board supervises the implementation of the provisions of the preceding paragraph.


The Supervisory Body of Frigerio Viaggi S.r.l., appointed pursuant to and for the purposes of art. 6, co. 1, letter b) of the Decree, is endowed with all the powers and duties provided for in the Organizational Model also in relation to the supervision of the punctual compliance with and concrete application of this Code of Ethics.

Frigerio Viaggi S.r.l. recognizes and respects the full autonomy and independence of the Supervisory Board in the exercise of its functions and guarantees its effective operation, including through the allocation of the necessary funds.

Among other things and in particular, the Supervisory Board is assigned the following functions:

  • Constantly monitor the application of the Code of Ethics by the Recipients, including through the examination of any reports received;
  • report any violations of the precepts enshrined in this Code to the relevant corporate functions, including for the purpose of applying appropriate sanctions;
  • Perform advisory functions in relation to the procedures to be implemented in order to ensure widespread dissemination and full implementation of the Code of Ethics within the Company;
  • Take care of the periodic updating of the Code of Ethics.




Frigerio Viaggi S.r.l. recognizes as a fundamental principle compliance with applicable laws and regulations wherever it operates.

Recipients are required, within the scope of their functions and in the exercise of their activities, to always comply with the rules of the legal system in which they operate and must refrain from committing violations of laws and regulations.

Each Recipient is required, with due diligence, to be familiar with the laws and regulations applicable to the performance of his or her duties, as in effect from time to time.

Each Employee must observe, in addition to the general principles of diligence and loyalty set forth in Article 2104 of the Civil Code, the behavioral prescriptions contained in the collective bargaining agreements applicable to him or her.


The Company, aware of the pre-eminent role that human resources play in the development of business activities, takes an active part in ensuring that human relations based on loyalty and mutual trust are established and maintained within the Company, as well as respect for workers' rights with a view to their full professional growth.

Each Corporate Officer, Manager, Employee and Collaborator is therefore required to act loyally, ensuring due performance and compliance with commitments made to the Company.


Each Recipient carries out his or her activities with the professionalism required by the nature of the tasks and functions performed, making every effort to achieve the objectives assigned to him or her and assuming the responsibilities incumbent on him or her by reason of his or her duties.

Each Recipient diligently carries out the necessary in-depth and up-to-date activities.

Mutual cooperation among those involved in any capacity in the same project or production process is an indispensable principle for the Company and an essential element for its success.

The quality and efficiency of the company's organization and the reputation of Frigerio Viaggi S.r.l. are determined to a significant extent by the conduct of each Recipient.

Each Recipient is therefore required by his or her conduct to contribute to the safeguarding of these values, both in and outside the workplace.


In the performance of his or her duties, each Recipient shall conduct himself or herself in a manner inspired by transparency and moral integrity (taking into account the various social, economic, political and cultural contexts of reference) and, in particular, by the values of honesty, fairness and good faith.


Each Recipient recognizes and respects the dignity, privacy, and personality rights of any other individual.

Each Recipient works with women and men of different nationalities, cultures, religions, ethnicities, and races.

Discrimination, harassment, or sexual, personal, or any other kind of offense will not be tolerated.

Acts of discrimination or even conduct aimed at inciting the commission of acts of discrimination on racial, ethnic, national or religious grounds are also not tolerated.

Propaganda, incitement, and incitement to discrimination on racial, ethnic, national, or religious grounds that is based, in whole or in part, on denial, gross minimization, or apologia of the Shoah or crimes of genocide, crimes against humanity, or war crimes shall also not be tolerated.


Each Recipient must keep adequate records of each transaction performed in order to be able to proceed at any time to verify the reasons and characteristics of the transaction in the stages of authorization, execution, registration and verification of the transaction.


Recipients, in the performance of their duties, shall avoid conflicts of interest.

By way of example only, the following constitute cases of conflict of interest:

  • the assumption of corporate offices or the performance of work activities of any kind (such as, for example, performance of works or services) with customers, suppliers, competitors and/or third parties in conflict with the interests of the Company;
  • The instrumentalization of one's functional position for the realization of interests conflicting with those of the Company;
  • the use of information acquired in the performance of work activities for one's own benefit or for the benefit of third parties and otherwise contrary to the interests of the Company.

Any situation that could potentially generate a conflict of interest or impair the Recipient's ability to make decisions in the best interest of the Company must be immediately communicated by the Employee or Collaborator to his or her Manager, or by the Manager or Company Representative to the Supervisory Board and determines, for the Recipient in question, the obligation to refrain from performing acts related to or relating to that situation.

This is, of course, without prejudice to the legal regulations on directors' interests (see Article 2391 of the Civil Code.[1]).

[1] Pursuant to Article 2391 of the Civil Code (relating to "Directors' Interests"), "The director must notify the other directors and the board of auditors of any interest he or she, on his or her own behalf or on behalf of third parties, has in a certain transaction of the company, specifying its nature, terms, origin and scope; if he or she is a managing director, he or she must also refrain from carrying out the transaction, referring it to the board of auditors; if he or she is a sole director, he or she must also notify the first useful shareholders' meeting. In the cases provided for in the preceding paragraph, the resolution of the board of directors must adequately state the reasons and the convenience for the company of the transaction. In cases of non-compliance with the provisions of the two preceding paragraphs of this article or in the case of resolutions of the board or executive committee adopted with the casting vote of the director concerned, the said resolutions, if they are likely to cause damage to the company, may be challenged by the directors and the board of auditors within ninety days of their date; the challenge may not be brought by those who consented with their vote to the resolution if the information obligations provided for in the first paragraph have been fulfilled. In any case, rights acquired in good faith by third parties on the basis of acts performed in execution of the resolution are not affected. The director shall be liable for damages derived by the company from his action or omission. The director shall also be liable for damages



Within the scope of their functions, Recipients are prohibited from offering or granting to third parties as well as accepting or receiving from third parties, directly or indirectly, including on holidays, unauthorized gifts, benefits or other utilities (including in the form of sums of money, goods or services), except for gifts of modest value directly attributable to normal relations of business courtesy and, in any case, such that they cannot create, in the other party or in an extraneous and impartial third party, the impression that they are aimed at acquiring or granting undue advantages, or such that they otherwise create the impression of illegality or immorality (without prejudice to the provisions of Paragraph 6 below. 4).

The Recipient who receives gifts, or offers of gifts, that do not comply with the above must immediately inform, in the case of Employee or Collaborator their Manager and the Supervisory Board, in the case of Manager or Company Representative the Supervisory Board, for the adoption of appropriate measures.

However, it is forbidden for the Recipient to solicit the offer or grant, or the acceptance or receipt, of gifts of any kind, even if they are of small value.

Any Recipient who, as part of his or her duties, enters into contracts with third parties must ensure that such contracts do not include or imply gifts in violation of this Code of Ethics.


In the context of relations with private entities, Recipients are obliged to refrain from offering, promising or paying, even through intermediaries, in the interest and/or to the advantage of the Company, undue money and/or any other utility:

  • to directors, general managers, managers responsible for preparing corporate accounting documents, auditors or liquidators of other entities, as well as
  • to persons who - within the organizational framework of entities other than the Company - perform management functions other than those proper to the persons indicated in the previous point (i) as well as
  • To persons subject to the direction or supervision of one of the persons specified in the preceding paragraphs (i) and (ii), so that they perform or omit acts, in violation of the obligations inherent in their office or obligations of loyalty.

It is also expressly forbidden to solicit, accept the promise or receive, for oneself or others, including through an intermediary, a promise or gift of money or other benefit not due in order to perform or omit an act in violation of the obligations inherent in one's office or obligations of loyalty.

Notwithstanding the above, in dealing with business partners and contractual counterparties, Recipients are required to carry out their activities with competence, precision, prudence, dedication and efficiency, as well as with honesty, loyalty, helpfulness and transparency and in compliance with the principles of this Code of Ethics.

In relations with business partners and contractual counterparts, all Recipients must also abide by the principles expressed in this Code of Ethics and, specifically, must:

  • establish business or contractual relationships only with individuals who enjoy a reputable reputation, who are engaged only in lawful activities, and whose corporate ethical culture is compatible with that of the Company;
  • Ensure transparency of agreements and avoid entering into secret pacts or agreements contrary to the law;
  • Maintain transparent and cooperative relationships with business partners and contractual counterparts;
  • Promptly report to one's superior and the Supervisory Board any behavior of the partner or contractual counterparty that appears contrary to the ethical principles set forth in this Code.

Frigerio Viaggi S.r.l., in carrying out its business activities, and in particular those concerning its core business, is committed to protecting the freedom of competition and its lawful implementation, guaranteeing the proper conduct of the economic order and stigmatizing any and all forms of intimidation through which one may tend to control, or otherwise affect, the business activities of others.

To this end, Recipients are expressly prohibited from:

- Spreading news about a competitor's business suitable for bringing it into disrepute or appropriating the merits of a competitor's enterprise;

- Make use, directly or indirectly, of any other means that do not conform to the principles of professional fairness and are likely to damage another's business;

- Implementing violent or intimidating behavior or conditioning the commercial, industrial or production activities of third parties, possibly even in the context of participation in public tenders, including with forms of intimidation typical of organized crime, in order to hinder/eliminate competition;

- Implementing collusive agreements with other companies, aimed at winning contracts, possibly including public contracts, to the detriment of other competitors, or discouraging competitors from submitting competitive bids.



Relationships with the press, television, and the mass media in general, including the social networks, whether domestic or foreign, shall be held exclusively by expressly authorized Corporate Officers or persons delegated by them from time to time.

All external communication shall be authorized in advance in accordance with the company's procedures in force from time to time and shall always be consistent with the Company's policy.


The Company, also in the context of its relations with the Public Administration (by way of example only: Ministries and their peripheral offices, Public Bodies, Local Authorities, Competition and Market Authority, Personal Data Protection Authority, etc.), requires all Recipients to strictly comply with the laws and regulations in force from time to time.

To this end, relations with the Public Administration are maintained by the Company Representatives or the Managers authorized to do so or by the persons delegated by them, in compliance with the laws and regulations applicable from time to time and with this Code, having particular regard to the principles of fairness, transparency and efficiency.

In particular, by way of example only, the following conduct and actions held or undertaken, in Italy or abroad, either directly by the Recipients or through persons acting on behalf of the Company, are prohibited:

  • Promise, offer or in any way pay or provide sums, goods in kind or other benefits, regardless of value, including through intermediaries, to public officials, public service officers or, more generally, public officials or employees in general of the Public Administration, with the aim of promoting or favoring the interests of the Company; and this not even following requests from persons belonging to the Public Administration, even if the latter, abusing their position or powers, engage in conduct aimed at inducing the Recipients to give or promise money and/or any other benefit. The aforementioned prescriptions cannot be circumvented by resorting to different forms of aid or contributions, such as appointments, consultancies, advertising, sponsorships, employment opportunities, business opportunities or any other kind, etc;
  • hold and undertake, even through an intermediary, such conduct and actions towards spouses, relatives or relatives-in-law of the persons described above;
  • behaving, even through an intermediary, in any case with the intention of improperly influencing the decisions of officials who deal with or make decisions on behalf of the Public Administration, for example by determining and/or instigating a public official to (or materially cooperating with him/her in) intentionally procuring an unfair pecuniary advantage for the Company or causing unfair damage to others in the performance of his/her functions or service and doing so in violation of specific rules of conduct expressly provided for by law or by acts having the force of law and from which no margin of discretion remains, or by failing to abstain in the presence of one's own interest or that of a close relative or in other prescribed cases;
  • Provide or promise to provide, solicit or obtain, even through an intermediary, information and/or documents that are confidential or otherwise likely to compromise the integrity or reputation of one or both parties in violation of the principles of transparency and professional fairness;
  • have a consultant or "third party" represent the Company when conflicts of interest may arise; in any case they, and their personnel, are subject to the same requirements that bind the Recipients.

The described behaviors are prohibited both during negotiations, requests or dealings with the Public Administration and once these are concluded.

In addition, in all cases of request to the State or other Public Entity or to the European Communities or to bodies of foreign states for contributions, subsidies, subsidized loans or other disbursements of the same type, however denominated, Recipients involved in such procedures must:

  • adhere to fairness and truthfulness, using and submitting statements and documents that are complete and relevant to the activities for which the benefits can be legitimately obtained;
  • once the requested disbursements have been obtained, allocate them to the purposes for which they were requested and granted.

Also for the purposes of all of the above, the Company requires Recipients to collect and retain documentation related to any contact with the Public Administration.


Relations with political parties, trade unions and other interest-bearing associations are maintained by the Company Representatives authorized to do so or by the persons delegated by them, in compliance with the laws and regulations applicable from time to time and with this Code, having particular regard to the principles of impartiality and independence.

In dealings with political parties, labor organizations and other interest-bearing associations, the behaviors and actions described in Section 6.4 are prohibited.

Strictly institutional forms of collaboration aimed at contributing to the realization of events or activities, such as conducting conferences, seminars, studies, research, etc., are permitted, as long as they are not intended to obtain undue favors.



The selection and management of personnel at Frigerio Viaggi S.r.l. are guided by criteria of merit, competence and evaluation of individual abilities and potential.

The Company rejects the use of illegal or undeclared labor.

The selection activity is also conducted in order to assess the correspondence of the personal and professional qualities of the candidates with the provisions of this Code.

Frigerio Viaggi S.r.l. enhances and tends to the development of the skills and abilities of its staff, including through the organization of training and professional development activities.

Each Recipient shall diligently carry out the above training and refresher activities, reporting any needs for additional or specific activities in order to enable the necessary steps to be taken by thel’Azienda.


It is the Company's goal to create a work environment characterized by the absence of racial, cultural, ideological, sexual, physical, moral, religious or other discrimination and to offer recipients equal opportunities on equal terms.

All Recipients are expected to cooperate to achieve this goal.


Recipients cooperate with each other in order to achieve common results and strive to create a peaceful and rewarding work environment.

Within the work environment, Recipients shall conduct themselves with seriousness, order and decorum.

All Recipients must avoid the use of foul, profane, and disrespectful language to those present or addressed.

Frigerio Viaggi S.r.l. strives to ensure that no incidents of harassment or intolerance occur in internal labor relations.

The dignity, as well as compliance with the regulations in force from time to time, of the conditions of employment of each worker, including in terms of health and safety protection in the workplace, as well as the relevant wage levels, must always be guaranteed.


The Recipients undertake to ensure punctual and full compliance with the regulations dictated on immigration and on the condition of foreigners in Italy, with particular reference to the provisions relating to the hiring process, whether fixed-term or open-ended, of foreign workers.

Among other things and in particular, the Recipients are required to refrain from any and all conduct that has the purpose, or even the effect, of hiring and employing in the employ of the Company foreign employees without a residence permit, or whose permit has been revoked or cancelled, or has expired (and whose renewal has not been applied for, within the terms of the law).


The performance of collateral activities by Recipients is permitted to the extent that they do not impair the performance by them of their work activities on behalf of the Company.

Recipients must, however, refrain from carrying out collateral activities (including unpaid ones) that conflict with their specific obligations to the Company.


The Company's property and, in particular, the facilities and equipment located within the workplaces, shall be used exclusively for service purposes, in accordance with current regulations.

The Company also carries out its activities in full compliance with the laws, including regulations, in force regarding the use and management of information systems, which the Recipients of this document are therefore required to know and respect.

Under no circumstances is it permitted to use corporate assets and, in particular, computer and network resources for purposes contrary to compulsory rules of law, public order or morality or otherwise aimed at racial intolerance, glorification of violence or violation of human rights, as well as to commit or induce the commission of crimes, to violate, damage or alter information systems or information of third parties, or to illegally obtain information of a confidential nature.

No Recipient is permitted to make audiovisual, electronic, paper or photographic recordings or reproductions of company documents, except in cases where such activities are part of the normal performance of his or her assigned duties.


The use of narcotics as well as the abuse of alcoholic substances in the workplace is prohibited.

Without prejudice to the regulatory provisions on smoking in the workplace, Frigerio Viaggi S.r.l. will give special consideration to the needs of those who ask to be preserved from contact with "second-hand smoke" in their workplace.

Frigerio Viaggi believes that a correct and educated lifestyle translates into consistent and correct actions of people in the workplace with an amplification of mutual respect between individuals as a necessary and inescapable premise for adequate and concrete action, both in the context of the development of more harmonious interpersonal relationships and in the context of the protection of people's health and safety in the environment and workplace.

Frigerio Viaggi refuses and sanctions any action contrary to the rules of this article and removes from the place, place and work environment anyone who gives signs of use or addiction to alcohol, narcotics or other substances that alter the person's state of consciousness.



Accounting transparency as well as the keeping of accounting records in accordance with the principles of truth, completeness, clarity, precision, accuracy and compliance with applicable regulations is the basic prerequisite for efficient control.

Accordingly, transactions and operations conducted must always be recorded in such a way as to ensure the accuracy, completeness and validity of the data, as well as compliance with the accrual principle and other applicable national and international accounting standards.

Verification of the process of deciding, authorizing and carrying out the aforementioned transactions and operations must also always be possible; therefore, there must always be adequate documentary support in order to be able to carry out, at any time, checks that attest to the characteristics and reasons for the operation and identify who authorized, carried out, recorded, and verified the operation itself.

The system of administration adopted by the Company must therefore be such as to ensure the regularity of management operations.

The company's accounting system must also ensure that every transaction of an economic/financial nature is recorded in accordance with the principles, criteria and procedures for the preparation and maintenance of accounts dictated by current regulations.

Each Recipient is required to cooperate in the proper and timely recording of all management activities in the accounts.


Frigerio Viaggi S.r.l. has taken as the fundamental values of its social actions those of transparency and fairness in fiscal matters. 

Recipients are in fact required to operate in full and complete compliance with the laws and regulations, from time to time in force, on tax matters, having regard - among other things and in particular - to the provisions on income tax and value added tax, and this also in the context of contractual relations with both Italian and foreign counterparts.

Frigerio Viaggi S.r.l. also requires Recipients to maintain, in the context of managing relations with the tax authorities, a correct, transparent and cooperative behavior.


Also in order to ensure functionality and efficiency, the Company implements a system of internal controls oriented to verify and guide the organization of the enterprise.

Each Recipient, within the limits of his or her assigned functions and duties, is responsible for the definition and proper functioning of this control system; among other things and in particular, he or she must keep adequate documentation of each transaction carried out, so that at any time the reasons for and characteristics of the transaction can be verified, in the stages of authorization, execution and registration of the transaction


The Company imprints its relations with the shareholders, auditors and auditors with the utmost diligence, professionalism, transparency, cooperation, helpfulness and in full respect of their institutional role, giving punctual and prompt execution to the requirements and any required fulfillments.

Data and documents are made available in a timely and comprehensive manner so as to provide accurate, complete, faithful and truthful information while avoiding and otherwise reporting, in the appropriate form and manner, situations of conflict of interest.


The Company requires Recipients involved, in whatever capacity, in its activities of importing and exporting goods to operate in full and complete compliance with the laws, including regulations, in force from time to time on customs law, having regard - among other things and in particular - to the provisions on border rights.

More specifically, any kind of activity (e.g., administrative-accounting and/or logistical in nature) however related to import and export transactions of goods must be carried out in such a way that it does not result in the effect of evading goods from the payment of border duties due.

Frigerio Viaggi S.r.l. strongly condemns any conduct aimed at bringing into a territory goods without having complied with the obligation to pay customs duties or evading monopoly duties, border surtaxes and any other similar taxes.



Frigerio Viaggi S.r.l. carries out its activities paying particular attention to the working environment and the safety of its staff and third parties, setting itself the goal of preserving the health of all Recipients to the best of its ability, including through the constant improvement of its performance in this regard, as well as taking care of the dissemination of a culture of safety for the encouragement of responsible behavior by all.

In particular, the Company is committed to full and constant compliance with the laws, including regulations, in force from time to time regarding the protection of health and safety in the workplace.

The responsibility of each Recipient to his or her fellow workers requires the utmost care to prevent injury risks.

Each Recipient, therefore, must take the utmost care in carrying out his or her activities, strictly observing all established safety and prevention measures to avoid any possible risk to himself or herself, his or her colleagues and third parties.

Recipients are required to comply with instructions and directives dictated by those to whom the Company has delegated the fulfillment of health and safety obligations in the workplace.


Frigerio Viaggi S.r.l. is committed to ensuring that the conduct of its business is always carried out with full respect for the environment and public health.

In accordance with the national and international legal and regulatory provisions in force from time to time, the Company requires that the activities of Recipients be constantly informed by the principles of ecological sustainability.

Each Recipient, in the performance of his or her functions and activities, is therefore required to comply with the environmental protection regulations applicable from time to time.

To this end, Frigerio Viaggi S.r.l. orients its choices in such a way as to ensure compatibility between economic initiative and environmental needs, not only in compliance with the laws, including regulations, in force from time to time, but also taking into account the development of scientific research and the best experiences in the field and favoring the use of less polluting raw materials and products.

In addition, as part of the activity of identifying and selecting service providers and consultants in environmental matters, Recipients are required to ascertain their competence, professionalism, transparency and reliability, including through the inclusion of special clauses in the relevant agreements.



No confidential information relating to Frigerio Viaggi S.r.l., acquired or processed by the Recipient in the course of or in connection with his or her activities in the Company, may be used, communicated to third parties or disseminated, even indirectly, for purposes other than those of the Company itself.

The notion of confidential information includes all data, knowledge, deeds, documents, reports, notes, studies, drawings, photographs and any other material pertaining to the Company's organization and assets, business and financial operations, research and development activities, as well as judicial and administrative proceedings related to the Company.

The obligation of confidentiality remains in effect even after the termination of the relationship with the Company, in accordance with applicable regulations and contractual provisions.

Any confidential information should be accessible only to authorized persons.


Frigerio Viaggi S.r.l. guarantees the processing of the information in its possession in full compliance with the legislation, including regulations, from time to time in force regarding the protection of confidentiality and personal data (including, in particular, the General Data Protection Regulation -EU Regulation 2016/679- and the Data Protection Code -D. Legislative Decree 196/2003-), guaranteeing its processing for purposes exclusively related to the performance of its functions.

The Company also ensures that they are stored in such a way as to prevent access to them by outsiders.

Frigerio Viaggi S.r.l. shall ensure that Recipients take care, within the scope of their functions, that personal data are processed in compliance with the regulations in force from time to time, as well as the company procedures applicable from time to time.


Frigerio Viaggi S.r.l. conducts its business in full compliance with current anti-money laundering regulations and the provisions issued by the competent Authorities.

To this end, Recipients must operate in compliance with company procedures and protocols, and avoid implementing transactions that are suspicious in terms of fairness and transparency.

In particular, the Recipients undertake to check in advance the available information regarding business counterparts, suppliers, consultants, etc., in order to verify their respectability and the legitimacy of their activities; they also undertake to operate in such a way as to avoid implications in operations even potentially conducive to the laundering of money from illicit or criminal activities, acting in full compliance with anti-money laundering regulations.

To avoid giving or receiving undue and/or improper payments, Recipients, in the performance of their duties, must comply with the following principles regarding documentation and record keeping:

  • all payments (and other transfers made by or to the Company) must be accurately and fully recorded in the statutory books and records;
  • all payments must be made only to parties with whom a contractual relationship has been established and for activities contractually formalized and/or approved by the delegated parties;
  • Traceability of the decision-making stages of financial dealings with third parties must be ensured.

Recipients are also expressly prohibited from using, substituting or transferring in economic, financial, entrepreneurial or speculative activities the money, goods or any other utilities deriving from the commission of a non-negligent crime committed by the Recipients themselves (or which has been committed even with their complicity), in such a way as to concretely hinder the identification of their criminal origin.

It is also expressly forbidden for Recipients to engage in any action and/or activity directed and/or otherwise aimed at manipulating payment instruments and digital monetary flows in order to procure an advantage for the Company.

Finally, it is expressly forbidden for the Recipients to unduly use credit or payment cards, or any other similar document that enables the withdrawal of cash or the purchase of goods or the provision of services, or in any case any other means of payment other than cash, in the interest of the Company, without being the holder.


In pursuit of the fundamental principle of respect for the law, Frigerio Viaggi S.r.l., among other things and in particular, expressly prohibits all conduct that may integrate - even potentially - the cases envisaged by the Decree.

In addition to the provisions of this Code of Ethics, the conduct described below is expressly prohibited.

Legal proceedings

Recipients, during the course of civil, criminal or administrative proceedings, shall not take (directly or indirectly) any action that may unduly favor or harm any of the parties to the proceedings.

Recipients are first of all prohibited from, among others, all behaviors and actions described in Section 6.4 above.

The Recipients are expressly forbidden to perform any action that may hinder the performance of the work of justice, such as inducing persons called upon to make statements before the judicial authorities not to make such statements or to make false statements, or helping someone to evade the investigations of the authorities or to evade the investigations of the authorities.

Computer or telematics systems

It is forbidden to gain unauthorized access to the information systems of third parties (private or public entities) or to alter their operation in any way or to intervene in any manner to which one does not have the right on the data, information or programs contained in a computer or telematic system or pertinent to it in order to unduly obtain and/or modify information for the benefit of the Company or third parties, or in any case for the purpose of procuring an undue advantage for the Company or third parties.

The Recipients are prohibited from altering in any way the operation of a computer or telematic system or intervening without right in any way on data, information or programs contained in or pertaining to a computer or telematic system, procuring the Company an unfair profit to the detriment of others.

It is also prohibited to illegally duplicate, for profit, computer programs or, for the same purposes, to import, distribute, sell, hold for commercial or entrepreneurial purposes or lease programs contained in media not marked by the Italian Society of Authors and Publishers (SIAE), or any means intended solely to allow or facilitate the arbitrary removal or functional circumvention of devices applied for the protection of a computer program, as well as enacting any other conduct, act or operation that may integrate, even if only potentially, an offense committed in violation of copyright law.

Associative crimes

The Recipients of the Code of Ethics must never promote, establish or organize associations aimed at carrying out acts, operations or behaviors capable of integrating, even if only potentially, hypotheses of crime, including the dealing of narcotic or psychotropic substances, the violation of regulations aimed at protecting the legal assets of fiscal transparency, the protection of environmental heritage, and the commission of other crimes (even if not covered in the context of crimes relevant under Legislative Decree No. 231/2001).

In particular, it is forbidden for each of the Recipients to promote, constitute, organize or join associations that make use of the intimidating force of the bond of association and the resulting condition of subjugation and code of silence to commit crimes in order to directly or indirectly acquire the management or otherwise control of economic activities, concessions, authorizations, contracts and public services or to realize unjust profits or advantages for themselves or others or in order to prevent or hinder the free exercise of voting or to procure votes for themselves or others during electoral consultations.

The Recipients of this Code must refrain from performing any act, operation or behavior that may integrate, even if only potentially, hypotheses of crime, including those not contemplated among the cases listed in Legislative Decree No. 231/2001, by taking advantage of the conditions referred to in the previous period or to facilitate the activity of the associations considered therein.

The Company strongly condemns any conduct aimed at promoting, constituting, organizing (or being part of) criminal associations aimed at committing any of the following crimes: reduction or maintenance in slavery or servitude (Article 600 of the Criminal Code), child prostitution (Article 600-bis c.p.), possession of pornographic material made using minors under the age of 18 (art. 600-ter c.p.), possession of pornographic material made using minors under the age of 18 (art. 600-quater c.p.), virtual pornography (art. 600-quater.1 c.p.), tourist initiatives aimed at the exploitation of child prostitution (art. 600-quinquies Criminal Code), trafficking in persons (Article 601 Criminal Code), trafficking in organs removed from a living person (Article 601-bis c.p.), purchase and alienation of slaves (art. 602 c.p.), sexual assault when the act is committed to the detriment of a minor under 18 years of age (art. 609-bis c.p.), sexual acts with minors (art. 609-quater c.p.), bribery of a minor (art. 609-quinquies c.p.), group sexual assault when the act is committed against a minor under 18 years of age (art. 609-octies c.p.), solicitation of a minor (art. 609-undecies c.p.), illegal immigration (Art. 12, para. 3-bis, D. Lgs. 286/98), crimes in the field of organ and tissue procurement and transplantation (referred to in Articles 22, paragraphs 3 and 4, and 22-bis, paragraph 1 of Act No. 91 of April 1, 1999)

Crimes against individual life and safety and crimes against individual personality

The Company firmly condemns any and all conduct aimed, even indirectly, at integrating any of the behaviors envisaged as crimes in Book II, Title XII, Chapters I and III, Section I of the Penal Code, and in particular the crimes of female genital mutilation practices (Art. 583-bis c.p.), reduction or maintenance in slavery or servitude (art. 600 c.p.), child prostitution (art. 600-bis c.p.), possession of pornographic material made using minors under the age of 18 (art. 600-ter c.p.), possession of or access to pornographic material (art. 600-quater c.p.), virtual pornography (art. 600-quater.1 c.p.), tourist initiatives aimed at the exploitation of child prostitution (art. 600-quinquies c.p.), trafficking in persons (art. 601 c.p.), purchase and sale of slaves (art. 602 c.p.), illicit intermediation and exploitation of labor (art. 603-bis c.p.), solicitation of minors (art. 609-undecies c.p.) and torture (art. 613-bis c.p.).


Crimes against copyright


Frigerio Viaggi S.r.l. operates in full and complete compliance with the legislation, including regulations, in force from time to time regarding the protection of copyright, having regard - among other things and in particular - to Law 22 April 1941, no. 633.


To this end, Frigerio Viaggi S.r.l. uses exclusively creative ideations or elaborations (such as, by way of example only, texts, sketches, illustrations, drawings, etc.), names and distinctive signs of which Frigerio Viaggi S.r.l. itself has the availability and the use of which falls within its availability, through a legitimate title to use (including by virtue of contractual agreements agreed upon with third parties).


Frigerio Viaggi S.r.l. also punctually applies the regulations in force regarding the protection and safeguarding of trademarks or distinctive signs or patents, models and designs. In this regard, in relations with third parties for which it is necessary, specific contractual clauses are provided to protect the parties, with reference to the correct application of current legislation on the protection and safeguarding of trademarks or distinctive signs or patents, models and designs.


Crimes against cultural heritage and laundering of cultural property and devastation and looting of cultural and scenic property

The Company firmly condemns any and all conduct aimed, even indirectly, at integrating any of the behaviors envisaged as crimes by Book II, Title VIII bis, of the Penal Code, and in particular the crimes of theft of cultural property (Art. 518-bis c.p.), embezzlement of cultural property (art. 518-ter c.p.), receiving cultural property (art. 518-quater c.p.), forgery in private writing relating to cultural property (art. 518-octies c.p.), violations regarding the alienation of cultural property (Art. 518-novies c.p.), unlawful import of cultural goods (art. 518-decies Criminal Code), unlawful exit or export of cultural property (Art. 518-undecies c.p.), destruction, dispersal, deterioration, defacement, defacement, and illegal use of cultural or scenic property (art. 518-duodecies c.p.), forgery of works of art (art. 518-quaterdecies c.p.), laundering of cultural property (art. 518-sexies c.p.) and devastation and looting of cultural and scenic property (art. 518-terdecies c.p.).


The Company undertakes to disseminate this Code of Ethics widely among the Recipients and to ensure its full and proper understanding, including through the provision of appropriate communication tools.


Violation of the principles contained in this Code gives rise, as the case may be, to a disciplinary offence (punishable in compliance with the applicable regulations) and/or a breach of contract, regardless of the possible initiation of criminal proceedings in cases of possible commission of offences, and may result in compensation for any damages resulting from such violation to the Company.

The sanctions are detailed in the General Part of the Organizational Model.

The Company guarantees that the sanctions provided for and possibly imposed for violations of this Code will be marked by respect for the principles of proportionality, consistency, impartiality and uniformity, and will also be taken in accordance with any applicable labor law provisions.

In the event of an ascertained violation of this Code of Ethics, the Supervisory Board will provide the relevant corporate functions with any and all appropriate suggestions for the improvement of the internal control system.


Frigerio Viaggi first adopted the Code of Ethics by resolution of the Company's Board of Directors on December 05, 2017; this first revision was approved by resolution of the Company's Board of Directors on December 05, 2022.

The Board of Directors on its own initiative or upon written and reasoned solicitation by the Supervisory Board reserves the right to make updates, insights and changes dictated by the needs that may arise from time to time and by the experience gained, to be submitted to the Frigerio Viaggi shareholders' meeting for ratification and approval.

Any proposal to update and amend this Code and, in general, the documents that make up the body of the Frigerio Viaggi Model will be submitted in advance to the Supervisory Board.

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