1- Corporate Governance
Reputation is of fundamental importance to the Medicalit Gate Bioscience. To this aim, it is necessary that during the running of business operations, the most appropriate principles of corporate governance are observed in order to ensure that the Medicalit Gate Bioscience activities are undertaken as efficiently as possible, in keeping with rules of sound corporate governance and the provisions of this Code of Ethics, Employees, Collaborators and all those persons entering into business relations and/or coming into contact with the Medicalit Gate Bioscience.

Medicalit Gate Bioscience is committed to meeting the highest possible standards when adapting to the provisions and principles of self-regulation laid down.

Accounting entries
Every operation or transaction is to be correctly recorded in the company accounting system, in accordance with the criteria indicated by law and all applicable accounting standards. It must also be authorized, verifiable, lawful, consistent and proper.

To this aim, Medicalit Gate Bioscience adopt accounting standards that meet requirements for truthfulness, completeness and transparency with regard to the data recorded; for every transaction effected, the inherent decision-making, authorization and execution process must be able to be verified, while adequate and complete documentation in support of the activity undertaken must also be stored as part of the Group’s official documents.

Each Employee is therefore required to co-operate – to the extent of his/her duties and responsibilities – so that any fact or event relating to the Medicalit Gate Biosciencemanagement is reported correctly and promptly to the competent functions and duly recorded in the relevant ledger.

Internal audit procedures
The term “internal audit procedures” means all instruments deemed necessary or useful for the purpose of steering, managing, verifying and realizing the activities of Medicalit Gate Bioscience, the underlying aim being to ensure that laws and business procedures are duly adhered to, in order to protect company assets, effectively manage business activities and provide truthful and correct information regarding the Medicalit Gate Bioscience property, performance and financial situation with transparency.

In this field is also included the checking the adequacy of business processes in terms of economy, efficiency and effectiveness and the reliability and accuracy of accounting records.

Mission of the Medicalit Gate Bioscience is to spread, at all levels, an internal culture characterized by an awareness of the existence of checks and geared to the pursuit of the control.

As part of their functions and responsibilities, the Medicalit Gate Bioscience Managers shall be required to partake in the realization and implementation of an effective business control system and to get all staff operating below them to become part of same system.

Medicalit Gate BioscienceEmployees shall therefore be required – to the extent of their duties and responsibilities – to:

define and ensure the correct functioning of the aforementioned control system;
responsibly look after all company assets (fixed and intangible alike) that are instrumental to the activities undertaken and ensure that they are not used improperly.
The Internal Audit Department and the Independent Auditing Firm appointed may freely access any data, documentation and information held useful in the undertaking of internal audit and accounting activities.

Anti Money Laundering
The Medicalit Gate Bioscience does not permit any kind of money laundering. Employees and Collaborators must verify in advance the moral integrity of the people with whom they have working dealings through a control of the information available. Medicalit Gate Bioscience is committed to conforming to all legal requirements relating to “anti-money laundering” in those countries in which the Medicalit Gate Bioscience operates.

 2- Confidential information, privacy protection and Insider Trading

 Confidential information and privacy protection

Medicalit Gate Bioscience activities constantly require data, documents and information regarding business negotiations, procedures, transactions and contracts to which the Medicalit Gate Bioscience is party to be obtained, retained, processed .

Each Employee is thus required to safeguard the private and confidential nature of the information acquired as part of his/her work duties, and – more specifically – to comply with the confidentiality clauses requested by Clients and other counterparties.

All information, knowledge and data acquired or processed by Employees by way of their duties belong to the Medicalit Gate Bioscience and may not be utilized, disclosed or divulged without prior and specific authorization being granted by a superior.

Each Employee shall:

obtain and process only the data that is necessary and directly related to his/her duties;

retain said data in such a way that outside third parties are prevented from becoming aware of it;

disclose and divulge data as part of procedures that are pre-established by the Medicalit Gate Bioscience or with prior approval of the competent person;

ensure that there are no confidentiality-related restrictions by virtue of relations of any kind with third parties.

Medicalit Gate Bioscience for its part undertakes to protect information and data relating to its Employees and to third parties, and to prevent said information and data from being used improperly.

To ensure that the privacy of all Employees and Collaborators is respected, the language used in communications and demand of personal data must be clear and unequivocal so that such persons can understand the request, the processing and storage of data. All standards adopted prohibiting to collect/disseminate personal data without the consent of the employee, except as required by law.

It does not include any investigation of ideas, preferences, privacy of workers.

 Insider trading

All Employees and external Collaborators who are not bound by an employment contract shall observe both domestic and international laws relating to insider trading.

With this in mind, price-sensitive information is of particular importance. Said information is to be disclosed to third parties – in accordance with the procedures adopted by the Medicalit Gate Bioscience– solely by those persons authorized to do so, and in any event in conformity with current legal provisions and pursuant to principles of the equality and contextuality of information.

No Employee or Collaborator not bound by an employment contract is to gain benefit of any kind (be it direct or indirect, personal or wealth-related) from using confidential information, where said information is not available within the public domain.

3-Model Anti-Discrimination Policy

Our Commitment on Discrimination

Medicalit Gate(“the Firm”) are committed to eliminating unlawful discrimination and

promoting equality and diversity in our own policies, practices and procedures and

in influencing others to do the same in our dealings with staff, clients, tenants, and

third parties.

We aim too treat everyone equally and with the same attention, courtesy and

respect regardless of their age, disability, gender, marital status, race, racial

group, colour, ethnic or national origin, nationality, religion, belief or sexual

orientation.

We are committed to complying in both letter and spirit with all anti-discrimination

legislation and associated codes of practice in force either now or in the future.

Unlawful Grounds for Discrimination

Discrimination on any of the following grounds is unlawful:

 age (in respect of employment matters only);

 race, racial group, colour, ethnic or national origins;

 gender, pregnancy, or marital status;

 disability;

 sexual orientation;

 religion or belief.

4- Forms of Discrimination

The following are the kinds of discrimination, which are against the firm’s policy:

(a) Direct discrimination, where a person is treated less favourably on the basis of

a ground which is unlawful;

(b) Indirect discrimination, where a provision, criterion or practice which seems to

be lawful would create a significant disadvantage for a substantial number of one

group of persons compared with other persons on the basis of an unlawful ground

unless that provision, criterion, or practice is objectively justified by a legitimate

aim and the means of achieving that aim are appropriate and necessary;

(c) Victimisation, where someone is treated less favourably than others because he

or she has taken action in respect of discrimination on unlawful grounds;

(d) Harassment, when unwanted conduct related to any unlawful ground takes

place with the purpose or effect of creating an intimidating, hostile, degrading,

humiliating, or offensive environment for any person. This is not limited to physical

acts and may include verbal and non-verbal communications and gestures.

Employment and Training

As an employer, we will treat all staff and job applicants equally and fairly and not

discriminate unlawfully against them. We will ensure, for example, that

arrangements for recruitment and selection, terms and conditions of employment,

access to training opportunities, access to promotion and transfers, grievance and

disciplinary processes, demotions, selection for redundancies, dress code,

references, bonus schemes, work allocation and any other employment related

activities do not constitute unlawful discrimination against any person or group of

persons.

Recruitment

We recognise the value of a diverse workforce and will take steps to ensure that:

(i) we recruit from the widest pool of qualified candidates possible;

(ii) employment opportunities are open and accessible to all on the basis of their

individual qualities and personal merit;

(iii) selection criteria and processes do not discriminate unjustifiably on any of the

unlawful grounds other than where we are exercising permitted positive action;

(iv) all recruitment agencies acting for the Firm are aware of this policy and act in

accordance with it.

Conditions of service

We will treat all staff equally and endeavour to create and maintain a working

environment which is free from discrimination and harassment and which respects,

wherever possible, the differing backgrounds and beliefs of employees. Terms and

conditions of service for employees will comply with antidiscrimination legislation.

The provision of any staff benefit such as working hours, leave and maternity leave

arrangements, performance appraisal schemes, bonus schemes, dress codes, or any

other conditions of employment will not discriminate against any employee on any

unlawful grounds. Where it is possible and reasonable to do so, the Firm will

endeavour to provide appropriate facilities and conditions of service which take

into account the specific needs of employees which arise from their ethnic or

cultural background; gender; responsibilities as carers; disability; religion or belief;

or sexual orientation.

Promotion and Career development

Promotion within the Firm will be made without reference to any of the unlawful

grounds and will be merit based. The selection criteria and processes for

recruitment and promotion will be regularly reviewed to ensure that there is no

unjustifiably discriminatory impact on any particular group. Although positive

action measures may be taken in accordance with the relevant anti-discrimination

legislation to encourage under-represented groups to apply for promotion

opportunities; recruitment, or promotion to all posts will be based entirely on

merit. All employees will have equal access to training and other career

development opportunities appropriate to their experience and abilities. However,

the Firm may take appropriate positive action measures where permitted or

required by anti-discrimination legislation to provide special training and support

for groups which are under-represented in the workforce and encourage them to

take up training and career development opportunities.