T2M structures its actions according to strong ethical principles, supported by a clear assumption of individual responsibility, as a lever aimed at fostering in all people working at T2M – in particular in Employees, Collaborators and Partners of the global Network – a full awareness of the consequences of their professional choices, for the benefit not only of themselves and of the Organization, but also of all other Stakeholders: Users of the platform and Workers also intended as an expression of human capital, Client Companies, Institutions, Local Communities, Suppliers, Competitors and any other economic and social interlocutor and of the labour market. Consistently with the structure of its Social Responsibility, T2M asks its Customers, Suppliers and Partners to read the Code of Ethics and invites them to share the respect of the lines of conduct indicated therein, operating according to the utmost mutual collaboration and aligning themselves with the principles indicated below.

LEGALITY

T2M works with Authorities and Public Institutions and with all other Stakeholders in compliance with the laws in force in the countries where it is present or where its services are distributed – on the basis of conduct inspired by the principles of transparency and fairness in contractual relations -, committing itself to uphold in its policies and working practices:

• the effective abolition of child labor;
• the elimination of all forms of forced and compulsory labour, and combating modern slavery and human trafficking practices;
• Workers’ freedom of association and the right to collective bargaining;
• the elimination of all forms of discrimination;
• compliance with all regulations governing the labour market, with regard to health and safety in the workplace, disciplinary procedures, working hours and remuneration;
• combating corruption in all its forms, including extortion and bribery.

 In particular, it is expressly forbidden for all company representatives to entertain undue relations with the Public Administration, including the exchange of money, favours or gifts, the perpetration of pressure, the issuing of false statements, or any other fraudulent behaviour that contravenes the law, even if carried out in the mistaken belief of pursuing the interests and objectives of the Company.

CONFIDENTIALITY

T2M protects the privacy of all stakeholders and the confidentiality of the information and personal data in its possession. All personal data collection, storage and processing operations may only be carried out by persons expressly authorized to do so, who operate under the direct authority of the owner or manager. The data must be collected and processed for specific, explicit and legitimate purposes, and according to the principles of adequacy, relevance, not excessive, and in any case the persons in charge authorized to the processing are required not to use any information for purposes not related to the exercise of business activities.

Considering the sensitivity of the information and documents processed (including behavioural profiles, organisational roles and functions, CVs and pay slips, commercial and employment contracts, climate surveys, headhunting activities, outplacement flows, etc.), all those who work within and in collaboration with T2M undertake to comply with the strictest confidentiality procedures to protect all those concerned, applying the laws in force in the country of activity and the agreed commitments, from the employment contract to collaboration agreements and specific non-disclosure agreements.

IMPARTIALITY

T2M bases its action on the principle of impartiality, in order to maintain a constant balance between the particular and general interests of the individual member of the human capital and of the Company, of each Employee, User, Customer, Partner and Supplier, recognizing and valuing diversity on the basis of mutual respect and common adherence to the values and principles of this Code of Ethics.

The principle of impartiality supports in particular the conduct of all those who work within and in collaboration with T2M:

• in the relationship with Employees, Candidates and Workers, where the selection, hiring, training, remuneration and management of human resources must be based exclusively on criteria of merit and competence, avoiding any type of discrimination, whether based, for example, on gender identity, religion, national or ethnic origin, cultural or social background, disability or illness, sexual orientation, age, marital status or political opinions;
• in the treatment of People, with respect to whom unlawful conditioning or undue discomfort is not allowed and working conditions that allow the development of personality and professionalism are promoted;
• in the relationship with the Customers, in order to be able to provide more and more qualitative services, taking into account the peculiarities of each one;
• in the relationship with Suppliers, where T2M does not intend to preclude anyone, who possesses the requirements to compete, the possibility of competing for the stipulation of contracts, opposing, on the other hand, commercial practices that induce the Supplier to sign a contract unfavourable to him.

HONESTY

T2M maintains that honesty is an essential condition to obtain credibility and to establish relationships of trust with all Stakeholders, which allow to improve the functioning, image and reputation of its business sector. Fairness and good management in business must permeate the actions of corporate representatives at all levels, outside and inside the Company:

• according to a conception of a humanistic market economy based on the centrality and respect for people (also understood as the human capital of modern and future societies), on free initiative and regulated competition, according to results and benefits of mutual interest and for the entire community;
• always acting with respect for the Company’s tangible and intangible assets, i.e. categorically avoiding the appropriation of any asset, data, commercial information, professional relationship with Users, Customers, Partners and Suppliers, which represent a company asset and as such must be managed, also in order to ensure the proper provision of services.

TRANSPARENCY

In acting, communicating and informing, T2M complies with the principle of transparency, which is a decisive element for obtaining reliability towards internal and external Stakeholders. Transparency represents a principle of conduct in particular:

• with respect to company management and contractual relations – whether with Clients, Partners or Suppliers, which must be fair, clear and verifiable;
• with respect to the costs of the services offered, which must be clearly expressed and that, as far as related to job search and insertion, the participants must not be charged in any way for the assessments invited by the commissioning companies and governmental or non-profit organizations;
• with respect to the communication of information about the Company to the outside world, which must also be truthful, simple, understandable, timely and accessible to all. In particular, no Employee or Collaborator is authorized to convey personal opinions in the name of the Company or of the operating entities of its global network, even through social media. The disclosure of information and data concerning T2M and each entity used to operate in its Global Network, as well as the use of logos, must be authorized by the function in charge.

HEALTH AND SAFETY

T2M undertakes to comply with all legal obligations regarding “Hygiene, Health and Safety”, starting from an accurate risk assessment and the definition of prevention and protection measures, in order to promote effective safety in the workplace – in terms of safety and security. All Employees, Collaborators, Partners, and whoever works in the name of and on behalf of T2M, without any exclusion, are bound:

• to comply with the regulations in force and to perform their duties in the field of health and safety, scrupulously complying with the specific work procedures laid down for their job in the country where they work: violations of regulations and laws on the subject are never tolerated for any reason;
• to undertake the commitment to proactively influence Colleagues on the safe behaviours to be implemented, acting as disseminators of the culture of safety in the workplace, including irreproachable personal and workplace conduct;
• the adoption of attitudes and behaviours marked by respect, civility, sobriety and good manners among colleagues and towards third parties.

T2M undertakes to intervene in order to prevent interpersonal attitudes that are offensive, insulting, discriminating or defamatory and prohibiting, without exception, dangerous behaviors, or behaviors that constitute physical and moral violence, immoderate use of bad language and verbal aggressions, harassment or mobbing episodes, applying the due disciplinary or sanctioning measures. T2M also requires its employees to be aware of the deleterious effects of the use of alcohol or drugs on their own health and on the health of others, both inside and outside the workplace. For T2M, this means safeguarding working conditions in order to protect the worker’s psychophysical integrity and to respect his dignity.

ENVIRONMENTAL SUSTAINABILITY

T2M develops its activity in compliance with all the laws and regulations in force for the protection of the environment, with the awareness that all companies, regardless of their core business, are called upon to implement good consumption practices that guarantee an optimal balance between the use of natural resources and their regeneration. The Company, in the analysis of the environmental impact of its activities, takes into account and monitors energy consumption, fuel consumption of the corporate fleet and consumables and sensitizes employees, partners and suppliers to operate according to the same principle.