Code of Ethics


The Code of Ethics is in line with the United Nations’ request to “embrace, support and implement that set of fundamental values regarding human rights, labour standards, the environment and anti-corruption” codified in the Universal Declaration of Human Rights, the International Labour Organization‘s Declaration on Fundamental Principles and Rights at Work and the Global CompactTen Principles on Human Rights, Labour, the Environment and Anti-Corruption. As a global operator of services aimed at enhancing human capital and then integrating its creation and value offer to the activities of the major global players in the field of selection, training and employment of present and future workers (multinational companies that typically adhere to the “World Employment Confederation), Time to Mind SA is inspired by and embraces the WEC Code of Conduct and recognizes the OECD Guidelines for Multinational Enterprises.

In this framework, this Code of Ethics expresses the set of values and principles that Time to Mind SA (hereinafter also “T2M”) has decided to adopt in the performance of its activities and in the relationship with all its stakeholders and represents an integral part of T2M’s Corporate Governance structure.

This document is issued and adopted by Time to Mind SA and will be considered valid for all Companies and local initiatives that will be born from it to develop and affirm the worldwide network of partnerships useful to the achievement of T2M Mission. All legal entities and strategic and operational collaboration that in the future T2M will constitute must formally share this Code of Conduct, conveying it with the most appropriate dissemination and training actions. The guidelines and principles contained herein will shape any possible second level code, any further regulation or policy, expressed by the single entities of the global Network in response to the compulsory requirements that regulate the activities of the different Countries, in order to detail the different aspects of the business and corporate relations.

The Code of Ethics is a binding point of reference to which Collaborators and Employees – starting with directors and managers – must refer to orient their daily work, actions and interpersonal relations within the Company and towards the community and the market. In no case may the conviction of pursuing the interests and objectives of the Company legitimize the violation of the rules of the Code of Ethics, which will prevail over any internal regulation, procedure or contractual relationship that may be in conflict with it.

T2M hopes that its Stakeholders recognise themselves in the values on which the Code of Ethics is based, that they share them and apply them as a basis for business management guided by the principles of integrity, loyalty, fairness, transparency, respect for the rules and the law, and absence of conflicts of corporate or personal interests.


Through the services of our multilingual IT platform and our Network of Partners operating worldwide, we want to contribute, as global players, to the evolution of human capital and education to the personal and social value of work.


The work of every single entity in the global Time to Mind SA network is based on a set of values that standardize T2M’s approach to the labour market and civil society within which, from time to time, it will operate.


We take great care and pride in what we do and believe that our work should always be carried out to the best of our ability, to create value for people, companies and ourselves, by providing immediate and satisfactory solutions.

T2M is aware of the public and social role of its Mission and pursues it daily with the utmost care and attention. Work must be done well, for oneself and for those to whom it is destined. In this context, the inspiring principle of T2M‘s activity is represented by the quality of the service oriented towards:

  • Clients, whether they are Companies, Workers or Young people in the orientation phase, public or non-profit organizations: to meet their specific needs with ad hoc tools and services, offering real, targeted, lasting solutions that create value, simplifying complexity;
  • the Person: to reinforce the recognition of its centrality and the awareness of the great importance that human capital constitutes and expresses through its correct and useful employment in the Labour Market. Always welcoming with respect every user of the T2M platform and of its Partner Network and taking care of them, with the conviction that the Company can have an educational role in people’s lives.


We are passionate about the work we do and each of us puts all our efforts to ensure that the needs, aspirations and goals of our Colleagues, Partners, Customers and Platform Users are met. “We, through our work, seek to participate in the struggle that all men and all peoples make to build a beginning of happiness.”

T2M conceives work as a means for the realization of the Person and his desires and as a participation in the construction of a greater Good that can last for the future. For this reason, T2M believes that the only valid way in which its Employees and Partners can carry out their work mission is by being passionate about human capital development methodologies and the consequent work opportunities that meet the needs and objectives of the People and Clients who turn to the services of our platform and our Network of qualified Partners.


In a rapidly evolving world, we are driven by curiosity and a sincere desire to learn, sharing our professional and personal knowledge to support the growth and evolution of our organization and all Stakeholders.

T2M is committed to developing the skills and competences of all employees, partners and platform users, stimulating the curiosity of individuals, protecting and enhancing the diversity that characterizes each one, so that the energy and creativity of individuals can find full expression, for the realization of their potential. Continuous learning and the appropriate application of improvements and innovations are necessary conditions to perform one’s job in the best possible way, creating new solutions able to respond to the evolution of economic and social conditions, in order to support the continuity of the company to the benefit of all Stakeholders. For this reason, T2M people make themselves available to Colleagues, Partners, Platform Users, Companies and Institutions, sharing their solid corporate and personal know-how, both through their daily professionalism and through appropriate dissemination and training channels, as well as through voluntary initiatives.


We believe that working as a team, fostering a culture of collaboration regardless of roles, is the way to achieve our ambitious goals and feel good about our work.

T2M believes that its key resource is its People, intended as a real expression of human capital, and that only their involvement in the corporate mission can allow it to be achieved. For this reason, T2M acknowledges the fundamental value:

  • internal communication and team spirit, to make work truly satisfying and increase the sense of belonging;
  • collaboration between employees and between organisational structures, based on mutual respect for professionalism, as the only way to achieve the common company objective;
  • the diffusion of Work-Life Balance and dialectical exchange with all Stakeholders, to ensure healthy and joint growth.

All T2M members – regardless of roles, responsibilities and seniority – are therefore called upon to create synergies and establish positive relationships with colleagues and Partners, openly discussing and making proposals to improve the services and processes of the platform and the company and create value for all stakeholders.




We grow by making sure that we always enhance our human capital and our financial and environmental resources, and with the future of the next generations in mind.

 T2M believes that the ability of a company to positively maintain its balance and performance conditions in the market is an essential constraint for a healthy business activity and for the achievement of the needs and goals of the Stakeholders.

The company’s growth must be based on the maximum enhancement of the resources entrusted to us, reconciling the protection of human capital, economic performance, social responsibility and environmental sustainability. T2M‘s people and Partners feel they are at the service of the reality that surrounds them and not the other way around: this is why they are committed to ensuring that the excellence of the service that must satisfy the needs of the present generation does not compromise, but rather strengthens, the possibilities for future generations to satisfy their own needs.


We promote respect for human rights and diversity and inclusion; we support all legislation that provides the greatest protection and safeguards for workers as an expression of human capital; and we play an active role in eliminating corruption and any form of abuse or misconduct.

T2M, as an international platform for the development of human capital in the world of work, is called upon to act as a primary interlocutor for Institutions and to actively participate in the definition of new and better rules for the development of the market and of Local Communities, favouring the import and export of global organisational best practices in the utmost respect for the law and according to the principle of free, regulated and fair competition. It is also aware that the Good it wants to build through its daily efforts falls under the individual responsibility of the company’s components and Partners. Everyone in T2M and in its international network of collaborations is called to act and communicate consciously, respecting the reputation of the company and of all the interested parties, supporting:

  • universally recognized human rights, actively safeguarding them;
  • diversity and social and labour inclusion, in compliance with the principles of equality, impartiality, protection of the dignity and safety of the person, and against all forms of discrimination;
  • the laws of the countries in which T2M services are used, combating abuse and corruption in all its forms;
  • standards that safeguard human capital and health and safety at work, propagating the culture and adopting the most effective prevention measures;

the environment, supporting the most advanced initiatives, technologies and practices aimed at preserving it


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.


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.


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.


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.


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.


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.


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.


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.



The Recipients of this Code are:

  • the members of the deliberative and control bodies of the Company, the Managers and the Employees belonging to the operative structures;
  • the Partners (Collaborators and External Consultants) who act in the name and on behalf of the Companies.

The provisions contained in the Code of Ethics are also addressed, where expressly provided for, to those external stakeholders with whom the Company and its operating entities of the global network have relations (Suppliers, Customers, Institutions, etc.).


It is in T2M‘s interest that the Code of Ethics be disseminated as widely as possible to all Recipients and third parties and that the principles and values it contains be shared. In order to guarantee the widest dissemination, it is published prominently on the company’s websites and intranet.

The managers and functional heads of the Companies must make the values and contents of the Code of Ethics explicit through their actions, taking care that they are perceived and pursued by everyone.

Employees, collaborators, partners and consultants must adapt their conduct to the values, principles, objectives and provisions contained in the Code of Ethics.

All Recipients and, to the extent applicable, also Customers and Suppliers and the other Stakeholders concerned shall be familiar with the provisions of the Code of Ethics, the reference regulations as well as the company procedures governing each specific internal function and shall be invited to comply with them.

To this end, T2M sets up appropriate training initiatives and invites all Recipients to request any information necessary for the correct interpretation of the Code of Ethics and for the application of the rules contained therein.


The control of compliance with, interpretation and verification of the principles contained in this Code of Ethics is delegated to the Legal Services department of the company, which has autonomous powers of initiative and control and is expressly charged with the following tasks:

  • supervise the application and functioning of this Code;
  • supervise the information and training of all Recipients;
  • propose and validate the update with respect to legislative changes and the evolution of activities and organization.

Each recipient is committed to report any behavior or circumstance that deviates from the principles of the Code of Ethics. Any situation or behaviour contrary to the provisions of this Code, of the internal procedures and laws in force that cannot be solved by acting in person or through recourse to one’s direct superior, must be communicated to T2M Legal Services (by e-mail to or by post to Time to Mind SA – Legal Services – Via San Gottardo, 10 – 6900 Lugano). The Company’s Legal Services function will ensure the utmost confidentiality in dealing with reports, in such a way as to guarantee anonymity and exclude any form of retaliation or discrimination against those who have reported violations of the Code; the Company’s Legal Services function will examine each report, proposing to the company departments concerned or even directly to the Board of Directors the adoption of the appropriate measures.

This Code takes effect from the date of its receipt by the parties to whom it is addressed.


Violation of the rules of this Code by Addressees damages the relationship of trust established with the Company and may lead to disciplinary, legal and possibly criminal action against them. In cases considered more serious, the violation may lead to the termination of the employment contract for employees and the interruption of the business relationship for Partners, collaborators and external consultants.


(items listed in order of appearance in the Code of Ethics)

Universal Declaration of Human Rights – On 10 December 1948, the United Nations General Assembly approved and proclaimed the Universal Declaration of Human Rights. The official text of the Declaration is available in the official languages of the United Nations, namely Chinese, French, English, Russian and Spanish. The Declaration has since been translated into 523 versions and world languages.

International Labour Organization (ILO) – The International Labour Organization (ILO) is a specialized agency of the United Nations dedicated to the promotion of social justice and internationally recognized human rights, with particular reference to labour rights in all their aspects. On 18 June 1998, the ILO adopted the Declaration on Fundamental Principles and Rights at Work and its follow-up, thus meeting the challenges of globalization, which have been the subject of extensive debate within the ILO since 1994. Although globalization is a factor in economic growth, and this in turn is an indispensable condition for social progress, the fact remains that it does not in itself guarantee such progress. It must be accompanied by certain basic social rules, based on common values, so that all the parties concerned can claim a fair redistribution of the wealth they have helped to produce.—europe/—ro-geneva/—ilo-rome/documents/publication/wcms_151918.pdf

United Nations Global Compact – is the world’s largest strategic corporate citizenship initiative. First proposed in 1999 at the World Economic Forum in Davos by former United Nations Secretary Kofi Annan, the “United Nations Global Compact” was launched operationally from the United Nations Building in New York in July 2000. Since then, more than 18,000 companies from 160 countries around the world have joined, creating a new reality of global collaboration.

OECD Guidelines for Multinational Enterprises – are recommendations addressed by governments to Multinational Enterprises. The Guidelines aim to ensure that the activities of Multinational Enterprises are consistent with government policies, to strengthen the basis for mutual trust between enterprises and the societies in which they operate, to improve the conditions for foreign investment and to enhance the contribution made by Multinational Enterprises to sustainable development. The Guidelines are part of the OECD Declaration on International Investment and Multinational Enterprises.

Stakeholder: any person (or group) with an influence on an economic initiative, a company or any other project. For T2M they are:

  • majority and minority shareholders;
  • directors and managers;
  • employees;
  • collaborators and partners;
  • suppliers and banks;
  • social creditors;
  • users of the platform as final customers and participants in assessments and post-assessments)
  • unions;
  • competing companies;
  • organizations and companies operating in the research, selection, training, development and organization of human resources;
  • institutions: municipalities, provinces, regions, government, schools, universities, political parties;
  • inhabitants of local communities and their associations: committees, associations, etc.

Global Network/Partner. The services of the T2M platform are promoted and spread on the global market thanks to a Network of collaborators linked to the Company by a “collaboration framework agreement” for “Partners”. The Partners are always organizations independent from T2M, which have the professionalism and competence necessary to operate effectively within the proper dissemination of the services offered by the platform Time to Mind and carry out their activities in a completely autonomous without any constraint of dependence and subordination from T2M.

Qualified Partner. They are those Partners who have completed a qualification path lasting 12 months that, from an operational point of view, enables them to carry out “remote” or “in-person” Post Assessment activities applying the “T2M method” on clients requesting this service from the platform. Furthermore, Qualified Partners may propose to T2M, insert, train and assist new “Partners” in their own territorial area of activity.

Offensive, Insulting and Defamatory Attitudes. “Offensive” is conduct that causes physical injury or creates intense feelings of fear, humiliation, manipulation or exploitation in other persons. “Insulting” is the type of offence given to the honour and decorum of a person who is present when the sentence is uttered; “defamatory” is the offence against the reputation of others committed by communicating with other persons, which must be at least two or more. In this case, the victim is usually not present.

Duty of Loyalty. The legal or moral responsibility of a person to promote the best interests of an organization or other person with whom he or she is associated.

Conflict of Interest. A situation that arises when a practitioner is faced with making a decision or carrying out an action that will benefit the practitioner or other persons or organisations to whom the practitioner owes a duty of loyalty and at the same time will harm other persons or organisations to whom the practitioner owes similar duties. The only way to resolve a conflict of interest is to disclose the conflict to the parties involved and allow them to decide how the trader should proceed.


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