Article 1
General principles

All addressees of this code of conduct must observe and comply with the following provisions, which form essential principles of the code imposed by the company, provided they relate to individual responsibility in the given situation. Thus, all shareholders in the company and all those who enter a new relationship with the company must:
a) act in accordance with applicable national statutory provisions, orders and any further statutory regulations in force in Italy, Europe or other states with which the company may work in any capacity.
b) protect the health of persons who are working for the company or working with the company for any reason.
c) diligently espouse the protection of the safety of persons who come into contact with the company as well as any third parties.
d) commit to preventing any damage to nature or the environment in which the company operates.
e) act in accordance with the principles of honesty, correctness, good faith and propriety when dealing with the members, employees, suppliers, customers and public administration as well as with third parties who have a relationship with the company.
f) take the greatest care to abide by current and future statutory regulations in the area of data protection in order to protect information of all kinds relating to customers, suppliers and employees as well as the technological know-how of the company.
g) contribute to the preservation of the company’s good name and corporate and management traditions, and commit to the goal of passing on collected experiences to those who will be engaged in the company with a particular competency or assignment in the future.
h) develop, promote and advance technologies relating to cable car transportation, cable car and piste safety, as well as snow-making on the pistes, while taking into account the environment in which the company operates.

Article 2
Provisions relating to management

2.1 Employee relations
Although the company continues to increase its access to the most modern technology, something that appears to be unavoidable in the exercising of its activities, it is mindful that considerable importance is to be ascribed to the development and safeguarding of human resources. The development of these human resources constitutes the basic element of the company for the purpose of supporting the experiences, further training and professional capabilities of each and every colleague, irrespective of their individual position.
There will be no discrimination on the basis of gender, ethical, religious or economic origin or membership, or on the basis of further characteristics that could discriminate one member of staff from another. This is especially applicable as the company’s obligation to offer all employees equal employment opportunities, professional support and career opportunities constitutes a basic element of the company, whereby company decisions are based solely on the evaluation of the professional competence and qualifications of the individual. Furthermore, the company is committed to contributing to the protection of the health and safety of members of staff at all times, by enabling them to work in a suitable working environment in which mutual co-operation and the desire for progress and development are the decisive factors.
The person charged with protecting employee relations also monitors the working conditions to ensure that they do not demonstrate any internal or external limitations, disadvantageous situations or other prejudices.

2.2 Customer relations
The company’s primary interest lies in providing services to the highest satisfaction of its customers, whereby it strives to constantly ensure that these services are of the best possible quality. In accordance with this criterion, the company has set itself the goal of ensuring ongoing adaptation to the latest technologies available in the field while also taking into consideration technological progress, market demand, funding and environmental protection, so as to guarantee state-of-the-art cable car transport services.
The company will exercise the greatest care in complying with provisions and principles at community, state and provincial levels. Likewise, the company will operate in accordance with standing agreements concerning Dolomiti Superski and Skirama in Eisacktal, within its field of competence.

2.3 Relations with suppliers and landowners
The company reserves the right to trade, negotiate and enter into contracts with suppliers of any type, whether Italian or foreign, without any discrimination, whereby decisions are made solely on the basis of the quality and technological standard of the goods and services offered and in a lesser respect, on the basis of generally applicable objective criteria. Decisions based on personal acquaintance or preference of any type, however, are not permitted and are strictly prohibited.
The company also applies the principle of equality and equal treatment to its annual and extraordinary reparations to landowners, whereby the relevant public guidelines (farmers’ association etc.) are used as a basis for the calculation of these reparations.

2.4 Relations with rival companies
The company must act with the highest possible standards of economic loyalty, and in all contractual or pre-contractual phases it must refrain from actions that could contravene generally applicable principles of free competition and the ban on unfair competition.
Likewise, the company will refrain from actions that are exclusively aimed at causing damage or competitive distortion to a rival company.

2.5 Relations with public administration
The art and manner of relations with public administration, whether it be at a state, regional, provincial or local level, is of essential importance to the company. Such relations must be distinguished by the highest levels of loyalty, correctness and transparency.
All those who come into contact with public administration in the name of and on behalf of the company must refrain from actions that could influence the decisions made by public administration; they are expressly forbidden to exert pressure of any kind to influence the decisions and resolutions made by public administration. It is forbidden at all times to give public administration employees direct or indirect advantages with the aim of influencing decisions made by public administration, which itself must act with the highest level of independence.
All external subjects that come into contact with public administration on a case by case basis must themselves adhere strictly and absolutely to these principles.

2.6 Gifts / Gratuities
In connection with the above-mentioned statements, it follows that the company is not allowed to give a gift to any person, whether it is a privately or publicly known person, with the intention of receiving more preferential conditions; only such gifts that are customary in normal business practice or can be attributed to principles of politeness are permitted. Gifts are also considered to include special contributions such as job offers, travel proposals etc.
Moreover, any form of contribution to public servants and officers of any grade or function within public administration or to their acquaintances and family members is forbidden in order to preserve their independence when evaluating and assessing relations that exist between the company and public administration. However, contributions and donations are permitted to third parties in which the company has no economic interest and which are manifestly being made solely to assist charitable or cultural initiatives or to provide sporting and humanitarian support, provided that such contributions and donations reflect the company’s image in a positive way; this is for the maintenance of appropriate control over all charitable activities.
All subjects who believe that they have received contributions and donations that do not conform with this code are requested to inform the president of the board of directors and the monitoring board immediately so that the legitimacy of the contribution can be verified and the necessary provisions can be made if appropriate.

Article 3
Maintaining safety

All addressees of this code are to actively exert themselves and ensure that the health and safety of all those working with the company for any reason are protected.
Any discrepancies that may be noted by internal or external subjects must be communicated to the president of the board of directors and the monitoring organ immediately so that they can take the necessary measures to improve the quality standards of the company.
In particular, the company prohibits the consumption of alcoholic drinks or drugs during the performance of work activities and immediately before the start of working hours; furthermore, in the light of applicable legislation, smoking in enclosed workspaces is forbidden. Any violations will be strictly sanctioned.

Article 4
Environmental protection

Taking into consideration the rural nature of the surroundings in which the company operates, environmental protection is a primary guiding principle for the company; to this end the company explicitly pledges to make decisions that best meet the needs of technological and entrepreneurial progress on one side and the needs of environmental protection on the other side. From case to case and according to need, the company will utilise part of its own resources so that the implementation of environmental protection is also safeguarded during the exercise of company activities, and all structures from cable cars to reservoirs and snow blowers encroach upon the landscape as little as possible and integrate with the natural landscape as well as possible.
All shareholders in the company and third parties who work with the company for any reason must pay great attention to make sure that no environmental pollution is caused, whether in the form of emissions, waste or residues. In equal measure, the protection of the environment in which the company operates is of essential interest for the company, whereby particular regard is shown for all animal and plant species.
Any person who disputes or queries the environmental friendliness of company activities may contact the president of the board of directors or the monitoring organ without delay.

Article 5
Data protection

All persons who enter relationships with the company for any reason (working relationships, business relationships, professional relationships) must keep any company information that comes into their knowledge strictly confidential and must not disseminate it in any way, so that all items of information, independently of each other, are the property of the company and will remain so.
Any illegitimate use and dissemination by third parties of information and data, the knowledge of which is exclusively reserved for the company, will be sanctioned by the company in accordance with the applicable statutory regulations: all freelancers who gain knowledge of information and data relating to the company such as the development of new transport and snow-making systems, strategy plans or future investments etc. are obligated to use such information exclusively in connection with the task given to them by the company and are to further commit themselves expressly not to pass on the information to third parties, family members or acquaintances, irrespective of the provisions of their own professional code. On its part, the company will commit itself to process all data that come into its knowledge in accordance with the data protection act, whereby it conscientiously observes the data protection act.
All data that the company obtains for any reason are and will remain its property and may be used solely and exclusively for the execution of business activity, provided such activity corresponds with the data protection act.

Article 6
Managing network resources

In order for the management and administration of the company to be kept up to date and the accounts to be registered rigorously and punctually, the company will deploy suitable technology, undertake appropriate modernisation and ensure that its EDP system is always adapted to future developments. The company deploys systems such as anti-virus software and firewalls to protect all network resources; this is also done to protect against viruses and prevent unwanted attacks by third parties on the internet.

Article 7
Company books and registers

The company administers and uses all company books that are designated in accordance with applicable civil and taxation legislation. In particular, the company uses the following books:
• minute book from meetings, book of decisions made by the board of directors, monitoring board record book, executive committee book, book of inspections by the monitoring board, inventory book, value added tax register, diary, members’ register, register of depreciable investments. These registers are updated in accordance with the legally prescribed terms, kept at the registered office of the company or at the external data processing office and are at the disposal of entitled persons for the purposes of inspection.
The complete registration and annotation of activities conducted is incumbent upon the company, which carries out compliance of recording with events as well as entering accounting documentation. The administration and storage of company books can also be given over to an external office/advisory company. This is to be recorded in writing so that the storage location of the company books is always traceable.
The accounting is carried out by an external data processing office that can ensure a high level of quality and effectiveness of entries through the use of the most up-to-date electronic systems.
The company furthermore guarantees that all accounting processes correspond to current fiscal principles and that the accounting procedures, recording, registration and general administration of company books and registers is regularly controlled and monitored.
All shareholders in the company must always consent to work with the monitoring board and the monitoring organ, and provide them on request with fiscal and accounting documentation, as well as documentation and records of any kind relating to the company, so that all control and monitoring activities can be carried out.

Article 8
Conflicts of interest

All persons acting directly or indirectly in the name and on behalf of the company or in its interests, must scrupulously observe the contents of this code and expressly refrain from any actions that could come into conflict with the interests of the company and its members and thus avoid all activities that are potentially likely to bring about conflicts of interest with the company.
The company ensures that the administrative bodies are not able to act in cases that could potentially constitute direct or indirect competition for the company, or to pass resolutions regarding items on the agenda that could bring about conflicts of interest with the company. The goal of the company is always to protect its assets and the interests of the members and to avoid all actions that are contradictory to this.

Article 9
Supervisory body within the meaning of legislative decree 231/2001

Alongside the general monitoring of the implementation of the code of ethics and conduct, to which every employee is bound, the company has established a supervisory body within the meaning of legislative decree no. 231/2001. This collegial body, appointed by the board of directors, is charged with monitoring, controlling, implementing and updating the organisational model and also this code of ethics and conduct.
The duties and capacity of the supervisory body are detailed in a designated section of the organisational, management and control model.

Article 10
Reporting infringements

All persons who come into contact with the company for any reason must report any ascertained or attempted violations of the organisational model or other statutory provisions by the persons involved, immediately, confidentially and in written form, to either the president of the board of directors, the president of the monitoring board or the monitoring organ, whereby these are to be substantiated as exactly as possible. To facilitate the notification process, a designated message box will be installed in both the Vals and Meransen offices, where the messages can be posted.
Those who, in good faith, report violations or disrespect of the organisational model or other statutory provisions are protected from any form of reprisal, discrimination or penalty. Non-disclosure of identity is guaranteed in every case, without prejudice to the obligations prescribed by law and the protection of the rights of the company, or to persons accused in error and/or in bad faith.

Article 11
Violation of the organisational model and statutory provisions; disciplinary measures

Non-fulfilment of the norms of this code of ethics, as well as intentional infringements and the omission of prescribed actions, can lead to non-fulfilment of the employment contract. In this case, all consequences and/or disciplinary measures compliant with current regulations and collective agreements are applicable. This also pertains to possible loss of employment and also to the duty to pay compensation for any damage suffered by the company.
The types of disciplinary measure are determined by the current regulations and collective agreements and matched to the severity of the infringement. It is to be understood, however, that the penalty must never be of such a nature as to damage the dignity of the person.
In the case of non-compliance with this code of ethics and conduct on the part of advisers, agents, staff or suppliers, the penalties are designated in the corresponding contracts.