COMPLIANCE

Aqrate S.r.l. has adopted organizational safeguards proportionate to its corporate structure, aimed at preventing the predicate offences relating to the administrative liability of entities under Italian Legislative Decree No. 231/2001, with particular attention to relations with Public Administrations, public tenders and public funding, suppliers, payments, privacy, cybersecurity and intellectual property.

1. General principles Aqrate S.r.l. operates according to principles of legality, fairness, transparency, good faith, responsibility, confidentiality and respect for people. All recipients of the Code of Ethics are required to act consistently with these principles.

2. Legality and fairness The company and all recipients comply with applicable laws, regulations, contracts, internal procedures and professional standards. Pursuing corporate interests through unlawful or improper conduct is prohibited.

3. Relations with Public Administrations, financial institutions and public bodies Relations with Public Administrations, financial institutions, public bodies, associations and technical organizations are managed with transparency and traceability. Statements, applications, reports and documents must be truthful, complete and verifiable.

4. Anti-corruption Offering, promising, giving, requesting or accepting money, benefits, favours or undue advantages, directly or indirectly, to or from public or private parties is prohibited. Gifts and courtesies are permitted only if they are of modest value, lawful, documented and not capable of influencing decisions.

5. Payment traceability Payments and receipts must be traceable, consistent with contracts or actual services, properly recorded and approved according to internal responsibilities. Unusual, undocumented payments or payments to parties other than the actual beneficiary are prohibited.

6. Clients, partners and suppliers Relations with clients, partners, consultants and suppliers are based on quality, fairness, transparency, respect for agreements and protection of confidentiality. Suppliers must be selected according to objective and documentable criteria.

7. Data protection and confidentiality The company protects personal data, corporate data, translations, datasets, technical and commercial information and any confidential information belonging to clients, partners and suppliers. Data is processed only for legitimate and authorized purposes.

8. Responsible use of AI Aqrate promotes the responsible use of artificial intelligence in language-related processes. AI solutions must support human work, improve quality and productivity, and not replace professional judgement when competent human review is required.

9. Intellectual property The company respects copyrights, software licences, know-how, trademarks, databases and third-party intellectual property rights. The use of assets, software, content or datasets without proper title, licence or authorization is prohibited.

10. Conflicts of interest Recipients must avoid situations in which personal, family or third-party interests may interfere with the interests of the company. Any potential conflict of interest must be promptly reported.

11. Safety and respect for people Aqrate promotes a safe, respectful and collaborative working environment. Discrimination, harassment, retaliation, offensive conduct or behaviour contrary to personal dignity are prohibited.

12. Reports and prohibition of retaliation Anyone who becomes aware of conduct that is not compliant with the Code of Ethics, with the principles of fairness and legality referred to in Italian Legislative Decree No. 231/2001, or with company procedures may submit a report by writing to compliance@aqrate.biz. Any form of retaliation against a reporting person acting in good faith is prohibited.