1.Our commitment

VAY tolerates no form of corruption, active or passive, towards public officials, public bodies or private companies. We comply with Italian law on the matter, including the criminal code provisions on corruption, article 2635 of the civil code on private-to-private corruption and law 190/2012.

2.Who it applies to

To the directors, employees and collaborators of VAY S.r.l., including the Cybernix division, and to anyone acting on behalf of VAY: suppliers, partners, consultants, intermediaries.

3.What is forbidden

• Offering, promising or giving money or other benefits to obtain or keep a contract, an authorisation or any advantage.
• Requesting or accepting money or other benefits in exchange for a decision, an order or favourable treatment.
• Doing the same indirectly, through relatives, intermediaries, consultants or partners.
• “Facilitation” payments to speed up procedures or services that are due anyway.

4.Gifts and hospitality

Small gifts and courtesies are allowed only if of modest value, indicatively no more than 150 euros, occasional, made openly and never linked to a pending decision, such as a tender or a renewal.

• Never money or equivalents (vouchers, prepaid cards), of any amount.
• Business lunches and events are allowed if reasonable and with a professional purpose.
• When in doubt, ask management before offering or accepting.

5.Relations with public administration

• In public tenders and contracts, including on MePA, we follow the required procedures and give truthful and complete information.
• We do not seek informal contact with those who evaluate or decide during a procedure.
• We offer no gifts or benefits to public employees beyond the limits of their code of conduct.

6.Suppliers, partners and intermediaries

• We choose who works with us on objective criteria and check their reliability.
• Fees are proportionate to the work done, documented and paid by traceable means.
• We ask suppliers and partners to comply with this policy.

7.Sponsorships and donations

Sponsorships and donations are decided by management, documented and made only to reliable organisations with a clear purpose. We do not fund political parties, movements or their representatives.

8.Accounting and payments

• Every transaction is recorded correctly and completely, with the supporting documents.
• No unrecorded funds, invoices for non-existent transactions or cash payments beyond legal limits.

9.Training

Everyone at VAY learns this policy from day one, and we cover it again in periodic training with concrete examples.

10.Reporting

Anyone who receives a suspicious request, or notices behaviour contrary to this policy, reports it to the chairman of the board or the sales director, orally or in writing, also confidentially. Nobody suffers consequences for a report made in good faith, or for refusing to pay a bribe, even if the company loses business.

11.Breaches

Breaches are assessed by management. For employees they may lead to disciplinary measures under the applicable collective agreement; for suppliers, partners and consultants, to the end of the relationship. Legal consequences remain unaffected.