1.Who it applies to

The code applies to the directors, employees and collaborators of VAY S.r.l., including the Cybernix division. We also ask suppliers, partners and consultants to follow it in the work they do with us or on our behalf.

2.Our principles

• Lawfulness: we comply with the laws and regulations in Italy and in every country where we operate.
• Honesty and fairness: we do not seek advantages by improper means, even when it might seem in the company’s interest.
• Transparency: we give clear, complete and truthful information to clients, colleagues and partners.
• Respect: we treat every person with dignity, without discrimination.
• Responsibility: everyone answers for their own choices and work.

3.Relations with clients

• We propose solutions that are truly useful to the client, not those that suit us best.
• Offers, contracts and quotes are clear: clients always know what they are buying and what it costs.
• We keep our commitments and say straight away if something is not going as planned.
• We listen to complaints and handle them seriously and within set times.

4.Confidentiality and data protection

To do our job we have access to clients’ systems and information. We use it only for service reasons, as strictly necessary, and keep a record of it.

• We process personal data in compliance with EU Regulation 2016/679 (GDPR) and Italian law.
• We do not disclose confidential information about clients, the company or colleagues, even after the working relationship ends.
• We do not use confidential information for personal gain or for third parties.

5.Information security

• We protect credentials: multi-factor authentication, passwords kept in the company password manager, never shared by email or chat.
• We use authorised, up-to-date and protected devices and software.
• We report any suspected incident at once, even a simple mistake: the sooner we act, the smaller the damage.
• We apply to ourselves the same security rules we recommend to clients.

6.People and workplace

• We guarantee equal opportunities in recruitment, growth and pay, without discrimination based on gender, age, origin, religion, orientation, disability or opinions.
• We do not tolerate harassment, intimidation or offensive behaviour, online included.
• We protect health and safety at work, at our offices and at clients’ premises, under Legislative Decree 81/2008.
• We invest in training: everyone’s skills are the quality of our service.

7.Suppliers and partners

• We choose suppliers and partners on objective criteria: quality, reliability, security, price.
• We ask them to follow principles consistent with this code.
• We neither accept nor offer personal benefits in exchange for supplies or contracts.

8.Conflicts of interest

We avoid situations where a personal interest, or that of relatives and acquaintances, could influence decisions taken on behalf of VAY. Anyone in such a situation, even potentially, informs management before acting.

9.Gifts, hospitality and corruption

We neither offer nor accept money, gifts or favours that could influence a decision. The rules are set out in our Anti-corruption policy, which is part of this code.

10.Company assets and tools

• We use computers, phones, vehicles and company tools with care and for work purposes.
• Software licences are respected: no unauthorised copies, either in the company or at clients.

11.Communication and social media

Only authorised people speak on behalf of VAY. On social media everyone is free to express themselves, but without disclosing confidential information or attributing personal opinions to VAY.

12.Environment

We reduce waste of energy and materials, prefer efficient cloud solutions and dispose of electronic equipment under the WEEE waste rules.

13.Reporting and compliance with the code

Anyone who notices behaviour contrary to this code can report it to the chairman of the board or the sales director, orally or in writing, also confidentially. Those who report in good faith suffer no consequences.

Breaches of the code are assessed by management and, for employees, may lead to disciplinary measures under the applicable collective agreement. For suppliers and partners they may end the relationship.