Code of ethics

The code of ethics of Unione Sportiva Sassuolo Calcio S.r.l (hereinafter the “Club”), defines the set of values and principals of conduct relevant to the Club, highlighting rights, duties and responsibilities of all individuals subject to the Code.

The present Code of Ethics (hereinafter the “Code”) is aimed at spreading and sharing these values and principals within the Club, as well as serve as a distinctive and qualifying element of the Club in third party relations.

In particular, a Club primary value is compliance with Sport ethics, understood as honesty, loyalty, fairness and respect of applicable laws.

The Code constitutes an integral part of the “Organisation, Management and Control Model” provided for under art.6 of Legislative Decree 231/2001 on the liability of legal persons. At the same time, the Code is an instrument apt to prevent unlawful conduct and other integral offences. It also constitutes compliance with art. 7 comma 5 of the Italian National Football Federation (hereinafter F.I.G.C) Statute.

The present Code aims to maintain an adequate level of fairness and ethics in the sphere of Club directional activities, through improved dissemination and sharing of the ethical principles previously stated:

  • in the Club’s internal relations
  • in relations, commercial or otherwise, between the Club and third parties outside of the sport system
  • in relations between the Club and third parties affiliated, registered or licensed by the F.I.G.C or other National Football Federations recognized by the Fédération Internationale de Football Association (“F.I.F.A”)

The present document has been approved by the Club’s management bodies, committed to ensuring its widest dissemination possible to all beneficiaries  and the general public through its publication at the following link

WHISTLEBLOWING POLICY

The Company, in accordance with the applicable regulations, provides free access to a dedicated on-line portal (Whistleblowing Portal) to those who intend to submit, in good faith, reports on unlawful conducts, misconducts or omissions, that constitute or may constitute a violation, or inducing to a violation, of the Code of Ethics, of the Model of Organization, Management and Control pursuant to Legislative Decree no. 231/01 adopted by the Company and its implementation documentation (e.g. Group policies and Company rules).

Reports are accepted also anonymously. The Company will prosecute Whistleblowers in case of Reports made in bad faith, with defamatory intent or not intended to be in line with a proper spirit of cooperation with the Company. Reports must be submitted to protect the integrity of the Company and must be detailed, based on precise and concordant fact-checking elements. Reports must be submitted responsibly, with the aim of pursuing common good and fall under the kind of non-conformities prescribed by the system in place. The Company recommend not to submit Reports for issues different from the ones abovementioned and, as a general prescription, suggest employees to solve conflicts, whenever possible, through communication, even informally, amongst colleagues and/or with the direct supervisor or the competent Functions within the Company.

WAYS OF SENDING REPORTS

Reports can be sent:

  • through the electronic mailbox dedicated to the Supervisory Body odv@sassuolocalcio.it;
  • in printed form, by ordinary mail to the Supervisory Body at the Company address;
  • using the online Whistleblowing Portal made available by the Company, which provides a guided information for the Whistleblower; the Whistleblowing Portal can be reached at segnalazioni.mapei.eu

It should be noted that the paper form, by regular mail, and the Whistleblowing Portal are the best ways aimed at fully guaranteeing the possible anonymity of the Whistleblower.

The access to the Whistleblowing Portal is in fact subject to the “no-log” policy in order to prevent the identification of the Whistleblower who wishes to remain anonymous: this means that the company’s computer systems are not able to identify the access point (IP address) even if you are logged in from a computer connected to your corporate network.

For each Report submitted, the Portal assigns a unique identification code that allows each Whistleblower to check its progress, anonymously. Similarly, if a Report is not adequately detailed, the recipients have the right to request the Whistleblower, using the Portal and always through that code, further details of what is reported.

Reports made through the Whistleblowing Portal are received by the Company’s Supervisory Body and by the Head of Corporate Internal Audit of the Mapei Group; the latters handle the Report in accordance with confidentiality principles set out in this Policy and verify its validity in accordance with its content.

WHISTLEBLOWER’S PROTECTION AND RESPONSABILITY

No retaliation, discrimination or penalty, direct or indirect, will affect those who have made a Report in good faith. In the case of Reports made through the Whistleblowing Portal, the anonymity of the Whistleblower is guaranteed, except in cases where the Whistleblower expresses his consent to disclose and without prejudice to legal obligations. There are also penalties for those who violate the Whistleblower’s protection measures.

There are penalties against the Whistleblower, whenever possible, in case of Reports made with willful intent or gross negligence that are false, baseless, with defamatory content or otherwise made for the sole purpose of harming the Company, the Reported or the ones affected by the Report. The Company may also take proper legal actions.

THE REPORTED’S RIGHTS

During the investigation and the verification of possible non-compliance, individuals who are the subject of the Reports may be involved or notified of this activity, but under no circumstances a procedure will be initiated solely based on the Report, in the absence of concrete evidence on its content. This could possibly be done on the basis of other evidence found and established from the Report itself.

PRIVACY AND DATA PROTECTION

Any personal and sensitive information contained in the Report, including those relating to the identity of the Whistleblower or other individuals, will be processed in accordance with the applicable rules for the protection of personal data.