Ethics & Compliance

At Leasys, integrity is essential to our business. Our Code of Conduct expresses this vision to our employees, business partners and all other interested parties.

Rolando D'Arco

Chief Executive Officer

We, members of the Leasys Group, come from different countries with diverse cultures and professional backgrounds. This is a source of personal pride and collective strength. We commit ourselves every day to creating a diverse and inclusive work environment that values the contribution of each individual to Leasys’ success.
Our Code of Conduct establishes the principles of our daily ethical behavior and describes how we interact with external parties, conduct business, combat corruption, and protect our Group’s reputation. With integrity, we ensure compliance with laws, regulations, and best practices that enable us to offer high-quality services to our customers. Integrity is a source of competitiveness, a foundation for our sustainable growth, and the way to build our reputation as a company that customers, employees, and stakeholders can trust and rely on.

BUSINESS ETHICS GROUP CODE OF CONDUCT

Code of conduct

The Code of Conducts sets the principle of Leasys daily ethical behaviours and describes how the company interactrs with external parties, conduct business, fight corruption and protect our Group reputation.

Welcome to our Code of Conduct. At Leasys integrity is essential to our business. Our Code of Conduct expresses this vision to our employees, business partners and all other stakeholders. The Code reflects the core values to inspire us to do the right thing in all circumstances. As a Leasys Group workforce member, the communities in which we conduct our business operations are all affected by our actions, and benefit when we do the right thing. Without guiding principles, it is not easy to always know how to identify the right path to take, or, when we identify it, to follow it. That is why we need guiding principles. At Leasys Group, one way we develop an environment that embodies the highest ethical standards in business conduct is through our Code of Conduct (the “Code”). The Code aims to ensure that all members of Leasys Group’s workforce act with the highest level of integrity, comply with applicable laws, and build a better future for our Company and the communities in which we do business. Leasys Group endorses the Universal Declaration of Human Rights published by the United Nations (“UN”), the International Labour Organisation's (“ILO”) Conventions and the Organisation for Economic Co-Operation and Development's (“OECD”) Guidelines for Multinational Companies. Accordingly, the Code is intended to be consistent with such guidelines. The Code is approved by the Board of Directors of Leasys S.a.s.. The Code applies to Leasys S.a.s. and its subsidiaries which are collectively defined as “Leasys Group” and applies to Leasys Group’s worldwide workforce. Although no document can possibly take into account all the particular ethical and legal dilemmas that you may encounter in the course of your work, the Code provides guidance that is meant to keep you on the right course, and to alert you when further guidance for individual situations may be necessary. Neither the Code nor any of the Principles, Policies or Procedures are intended to, and do not create any contractual rights enforceable against Leasys Group by any workforce member, shareholder, customer, supplier or other third party. They help each of us to know what is expected of us as workforce members to make sure we act knowingly and with integrity.

The Code applies to all board members and officers of Leasys S.a.s and its subsidiaries, as well as fulltime and part-time employees of the Leasys Group and all its subsidiaries. The Code also applies to all contracts and all other individuals and companies that act on behalf of Leasys Group, wherever they are located in the world. We refer to this group collectively as our “workforce.” 6 Leasys Group has a global workforce located in many countries with varying legal requirements. In addition, some of our contract personnel may be governed by additional policies of their direct employer. While we recognise the diversity and complexity of the rules that apply to our workforce’s conduct, we do not expect that the Code will conflict with the expectations inherent in such rules. Leasys Group shall use its best efforts to ensure that the Code is regarded as a best practice of business conduct and observed by those third parties with whom it maintains business relationships of a lasting nature such as suppliers, dealers, advisors and agents.

Customer and Supplier relations

All employees are expected to observe high-level standards of professional and business conduct and encourage others to do the same. They shall act in integrity with Group values, the applicable laws, the industry's professional standards and internal regulations. They have to be able to demonstrate competence, diligence, respect and ethical manner in their relationship with Leasys Group’s customers. They shall avoid any misconduct and shall protect Leasys Group’s reputation and business sustainability. Moreover, they shall support the customer's needs using digital tools and applications available to the Group, in order to create value for the clients, putting the customers' satisfaction first. All employees, in day-by-day activities, shall observe the following statement according with their own responsibility and job:

Fair dealing and miss-selling

Engagements with the customers, marketing and sales documentation should always be based on values of fairness and transparency. Recipients shall not execute incorrect sale of products or services in circumstances where the contract is unclear, or the product / service is not suitable for the customer's needs.

Customer's needs

Employees shall take proper actions to undestrand the customer's needs and expectations. They shall make reasonable effort to support the customers in finding an advantageous solution for both parts. Employees cannot use customer or other external information acquired in the course of their working activity for executing personal dealings or obtaining any personal benefit despite of the customer's needs / expectations.

Customer's complaints

Employees should address and investigate customers' complaints in order to guarantee that customers' needs are heard, filtered through the Organization, and that are addressed in future product and processes definition, marketing, sales and advice.

Product governance

Product design, marketing, sales and advice should be driven by concerns about what the customer needs and what is most suitable for these needs combining with sales mindset. Post sales customer care should ensure customers' satisfaction or ongoing product suitability rather than focus the attention on commercial guidelines only.

Social, Environmental and societal issue

In a context where people are being increasingly required to communicate their personal data in paperless form, Leasys Group places importance to integrity, reliability, ethics and transparency over the use of personal data. As an employer, Leasys Group guarantees its employees the protection of their personal data and respect for their privacy.

Anti-corruption

Leasys Group is committed to the highest standards of integrity, honesty and fairness in all internal and external affairs and will not tolerate any kind of bribery. The laws of virtually all countries in which Leasys Group operates prohibit bribery. Leasys Group's policy is that no one - directors, officers or other employees, agents or representatives - shall, directly or indirectly, give, offer, request, promise, authorise, solicit or accept bribes or any other perquisite (including gift or gratuities with the exception of commercial items universally accepted in an international context of modest economic value, permitted by applicable laws and in compliance with the Code and all applicable Policies and Procedures) in connection with their work for Leasys Group at any time for any reason.

Protection and reputation of the group

Leasys Group ensures confidentiality in all circumnstances and applies to all types of media. All Leasys Group's employees are the custodians of and responsible for the confidential information they receive. Employees may use this information internally for professional purposes and make disclosures outside the Company only if authorised to do so or in the cases privided for by law. They ensure the security of its confidential data by exclusively using the devices made available by the Group. Leasys Group's employees must also apply the principle of confidentiality with the utmost rigour when using social media. They are responsible for everything they publish on the Internet regarding the Group and must ensure not to disseminate any information via the Internet that they would not divulge outside of Leasys Group by any other means. This principle of confidentiality also applies to business social networks.
BUSINESS ETHICS & COMPLIANCE

Compliance Program

In order for the Leasys Group to be fully in compliance with the provisions of the Italian Legislative Decree n. 231/2001, Leasys adopted the 231 Guidelines, which are addressed to the Intended Users of any company belonging to the Leasys Group and are articulated as an executive summary of the 231 Model adopted by Leasys. For a comprehensive knowledge of the 231 Model, all Intended Users of Leasys Group should refer to the 231 Model itself.

231 Guidelines     MOG Leasys