Preamble: The Purpose of the Code of Ethics
In order to guarantee maximum fairness and transparency in the management of its activities and to protect its image and reputation, the Ferrara Buskers Festival Association has prepared this Code of Ethics. It clearly defines the set of shared values, rules, and principles of conduct that inform the Association’s relationships with its personnel and third parties and characterize the performance of its activities.
The Code of Ethics is a useful tool to preserve the value and integrity of the Association over time. It is a set of positive principles and rules of conduct that the Ferrara Buskers Festival Association has chosen to adopt as a concrete expression of its intentions towards the entities and individuals with whom it comes into contact. The Code must inspire the activities of all those who work within the Association, taking into account the importance of their roles, the complexity of their functions, and the responsibilities entrusted to them to pursue the Association's goals.
Thoroughly knowing the Code of Ethics is therefore a duty, just as applying it is a duty. The reputation, smooth operation, and reliability of the Association are the result of everyone's joint and individual attention.
While providing a wide range of guidelines regarding standards of integrity and conduct in activities, this Code—an essential element in preventing offences provided for by Legislative Decree No. 231 of June 8, 2001 and Law No. 190 of November 6, 2012—is not to be considered a substitute for individual responsibility and the commitment of each person to act with common sense. Indeed, the Code represents a guide and support to pursue the mission of the Ferrara Buskers Festival Association in the most effective manner. Human resources at all hierarchical or functional responsibility levels, as well as third-party collaborators of the Ferrara Buskers Festival Association, are therefore called upon to strictly observe the rules and standards of conduct contained in this Code.
The Code of Ethics, which was also prepared in relation to the Association's compliance with anti-corruption regulations under Law No. 190 of November 6, 2012, forms an integral part of the Ferrara Buskers Festival Association’s corruption prevention framework. It aims to base operations, conduct, and working methods on fairness, equity, integrity, loyalty, and rigor—both in internal relations within the Association and in relations with external parties—placing respect for organizational procedures at the center of attention.
The Ferrara Buskers Festival Association carefully monitors compliance with the Code of Ethics by providing adequate information, prevention, and control tools, ensuring the transparency of operations and behaviors implemented, and intervening, where necessary, with appropriate corrective actions and sanctions.
Art. 1 – Addressees of the Code of Ethics
The rules of this Code apply, without exception, to the President and members of the Board of Directors, Members and their assembly representatives, collaborators, consultants, and all those who, directly or indirectly, permanently or temporarily, establish collaboration relationships or interactions with the Association in any capacity, however named, or operate in its interest. These individuals and entities shall hereinafter be referred to as the "Addressees".
Art. 2 – General Principles of Conduct
Observance of the law, regulations, statutory provisions, ethical integrity, and fairness is a constant commitment and duty for all those operating within the organizational structure of the Ferrara Buskers Festival Association.
All actions, operations, and negotiations carried out and, in general, behaviors displayed in the performance of work activities, are inspired by maximum fairness, completeness, and transparency of information, formal and substantive legality, and the clarity and truthfulness of accounting documents in accordance with applicable laws and internal procedures.
All activities of the Ferrara Buskers Festival Association must be carried out with professional commitment and rigor, with the duty to provide professional contributions appropriate to assigned functions and responsibilities, and to act in such a way as to protect the prestige and reputation of the Association.
Everyone operating within the organizational structure of the Association, without distinction or exception, must conform their actions and conduct to the principles and contents of the Code within the scope of their functions and responsibilities, in the awareness that compliance with the Code constitutes an essential part of the quality of work and professional performance. Relations among all those operating at every level within the Ferrara Buskers Festival Association must be based on criteria and conduct of honesty, fairness, collaboration, loyalty, and mutual respect.
Under no circumstances can the belief that one is acting to the advantage or in the interest of the Ferrara Buskers Festival Association justify, even in part, the adoption of behaviors in conflict with the principles and contents of the Code.
Corrupt practices, improper favors, collusive behavior, and direct and/or indirect solicitation of personal or career advantages for oneself or others are strictly prohibited without exception. The Ferrara Buskers Festival Association takes care to adequately inform third parties about the commitments and obligations imposed by the Code, demanding that they respect the principles directly concerning their activities, and adopts appropriate internal—and, where within its domain, external—initiatives in the event of non-compliance by third parties.
Art. 2.1 Respect for the Individual
The Ferrara Buskers Festival Association respects the fundamental rights of individuals and guarantees equal opportunities for all without any discrimination. The Association recognizes the centrality of human resources and protects and promotes their value. To this end, it commits to implementing all initiatives that allow for the enhancement and growth of skills, creativity, and active participation of each individual, in order to increase motivation and foster professional growth and personal fulfillment.
Art. 2.2 Promotion of Culture
The Ferrara Buskers Festival Association commits to promoting, encouraging, and increasing the education, training, professional development, and orientation of those who intend to devote themselves, or are already devoted, to cultural activities related to music and performing arts.
Art. 2.3 Protection of Health and Safety in the Workplace
Conscious of the importance of ensuring the best health and safety conditions in the workplace, the Ferrara Buskers Festival Association commits to spreading and consolidating a culture of safety. It does so by developing risk awareness, promoting and demanding responsible behavior among its collaborators, and resorting to appropriate preventive actions in order to safeguard the safety, health, and physical integrity not only of its personnel, but of all those who visit its premises.
The Ferrara Buskers Festival Association systematically reiterates the importance of health and safety through training and communication sessions, as well as constant updates of methodologies and systems, conducting specific assessments of risks, processes, critical points, and resources to be safeguarded.
Art. 3 – Criteria of Conduct
Art. 3.1 Relations with Members, the Board of Auditors, the Auditing Firm, and Other Statutory Bodies
As part of initiatives aimed at ensuring operational transparency, the Association defines, implements, and progressively adapts a comprehensive and uniform system of rules of conduct concerning both its internal organizational structure and its relations with members and third parties. This is done in accordance with the most advanced corporate governance standards in national and international contexts, recognizing that the Association’s ability to set efficient and effective operating rules is an indispensable tool to strengthen its reputation for reliability and transparency, as well as the trust of all those who interact with it.
Collaborators of the Ferrara Buskers Festival Association are required to guarantee maximum cooperation and transparency in relations they may be called upon to maintain with the Officer for Corruption Prevention and/or other bodies potentially competent in the matter, with respect to control activities exercised by them to enable them to perform their functions properly.
In particular, Association collaborators must refrain from engaging in conduct that prevents or hinders the performance of institutional and control duties of the Corruption Prevention Officer, Auditors, or Members, through concealment of documents or the use of other fraudulent means.
Furthermore, Addressees shall not engage in any conduct—even through intermediaries—aimed at influencing the independence of judgment of entities responsible for control activities.
Art. 3.2 Relations with Collaborators
The Ferrara Buskers Festival Association recognizes the centrality of human resources and the importance of establishing and maintaining relationships based on mutual trust.
Each collaborator, in performing their duties, is required to comply with the rules of this Code, without prejudice to the rules governing employment relationships under national and company collective bargaining agreements, as well as any additional special regulations.
In the various stages of managing relationships with its collaborators, the Ferrara Buskers Festival Association is guided by the following principles:
· Mutual Respect: It is the policy of the Ferrara Buskers Festival Association to foster an internal environment of civil coexistence in which every collaborator interacts with other colleagues honestly, with dignity, and with mutual respect.
· Ethical Conduct: Every human resource is required to perform their duties in a responsible, honest, diligent, and sound-judgment manner, in compliance with the procedures and directives established by the Association. The Ferrara Buskers Festival Association intends to adhere to the highest ethical standards in conducting its activities; therefore, each individual must avoid conflict of interest situations or other circumstances potentially harmful to the Association. Even the mere appearance of a lack of integrity must be avoided.
Art. 3.3 Recruitment and Selection of Personnel
The evaluation of personnel to be hired is carried out based on the match between candidates' profiles and expected company needs, respecting equal opportunities and equality for all interested parties. Recruitment and selection of personnel are conducted solely on the basis of criteria of objectivity, fairness, and transparency. Information requested is strictly linked to verifying aspects required by the professional and psycho-aptitude profile, respecting the candidate's privacy and personal opinions.
Art. 3.4 Establishment of the Employment Relationship
Upon establishing the employment relationship, the collaborator must receive comprehensive information and training regarding the characteristics of the duties and position, regulatory and compensation details, and rules and behaviors for managing health risks. All personnel must be employed in accordance with legal obligations. Indeed, the Ferrara Buskers Festival Association's policy on personnel and the engagement and/or contracting of collaborators in any capacity respects relevant regulations, within the framework of its broad conception of the internationality of art and music, and the freedom of movement and expression of all human beings.
Art. 3.5 Personnel Management
The Ferrara Buskers Festival Association avoids any form of discrimination against its collaborators. Within personnel management and development processes, as well as during the selection stage, decisions made are based on the match between expected and actual skills of collaborators and/or on merit considerations. Access to roles and assignments is also determined considering skills and capabilities; furthermore, consistent with general operational efficiency, workplace flexibility that facilitates maternity management and child care in general is encouraged.
Art. 3.6 Enhancement of Human Resources
The Ferrara Buskers Festival Association ensures that its collaborators are suited for the functions to be performed and professionally qualified, utilizing available levers to support their development and growth. Specifically, it provides all collaborators with information and training tools aimed at enhancing specific skills and preserving the professional value of personnel.
In this context, communication by managers regarding a collaborator's strengths and weaknesses is of particular importance, so that the latter can work towards improving their skills, including through targeted training.
Art. 3.7 Collaborators in Positions of Responsibility
Anyone holding a managerial or leadership role must set an example for others and demonstrate through their behavior that compliance with the Code is a fundamental aspect of their work. They must also:
· Ensure compliance with the Code by their direct subordinates;
· Work to ensure that collaborators understand that provisions contained in the Code form an integral part of their work performance;
· Report every instance of non-compliance with the Code, protecting those who made good-faith reports of violations, and adopt and apply sanctions proportionate to the violation committed and sufficient to act as a deterrent against further violations.
Art. 3.8 Management of Collaborators' Working Time
Every manager is required to value the working time of collaborators by requesting performance consistent with the exercise of their duties and work organization plans. Requesting performance,
personal favors, or any behavior constituting a violation of this Code as a duty owed to a hierarchical superior constitutes an abuse of authority.
Art. 3.9 Collaborator Involvement
Collaborator involvement in carrying out work is ensured, including by providing opportunities for participation in discussions aimed at achieving company goals. The collaborator must participate in these moments with a spirit of collaboration and independent judgment. Listening to various points of view, compatible with organizational needs, allows the manager to make final decisions; nevertheless, the collaborator must always contribute to the implementation of established activities.
Art. 3.10 Integrity and Personal Protection
The Association commits to protecting the moral integrity of collaborators by guaranteeing the right to working conditions that respect personal dignity. For this reason, it safeguards workers from psychological violence and opposes any discriminatory, harmful, or offensive attitude toward individuals, their beliefs, or their preferences (e.g., insults, threats, isolation, excessive intrusiveness, or professional limitations). Sexual harassment is firmly condemned, and behavior or language that could distress a person's sensitivity must be avoided.
Collaborators who believe they have been subjected to harassment or discriminated against based on age, sex, sexuality, race, health status, nationality, political opinions, or religious beliefs may report the event to the Corruption Prevention Officer, who will assess whether an actual violation of this Code occurred.
Art. 3.11 Duties of Collaborators
Collaborators must act loyally in order to comply with the obligations undertaken in their employment contracts and the provisions of this Code, providing the required performance.
Art. 3.12 Information Management
Collaborators must know and implement company policies on information security to guarantee integrity, confidentiality, and availability. They are required to draft their documents using clear, objective, and comprehensive language, enabling potential audits by authorized internal or external entities.
Art. 3.13 Protection and Use of Company Assets
Every collaborator is required to safeguard company assets by protecting movable and immovable property, technological resources, IT media, equipment, information, and/or the know-how of the Association.
In particular, every collaborator must:
· Act diligently to protect company assets through responsible behavior aligned with operating procedures established to regulate their use, strictly observing all security programs to prevent unauthorized use or theft;
· Avoid improper use of company assets for purposes contrary to mandatory legal provisions, public order, or morality, as well as to commit or incite the commission of crimes and/or racial intolerance, the glorification of violence, or human rights violations; obtain necessary authorizations if an asset is to be used outside the corporate scope.
Art. 3.14 Use of IT Systems
The use of IT tools in performing work duties is subject to the conditions set out in licensing agreements, applicable legal provisions, and the principles expressed in this Code.
Personnel are therefore expressly forbidden from installing borrowed or unauthorized software on company systems, or making unauthorized copies of licensed programs for personal, corporate, or third-party use.
Individuals operating within the Ferrara Buskers Festival Association in senior or subordinate positions are strictly prohibited from altering the operation of IT and telecommunication systems in any way, or illegally tampering with equipment, data, information, and programs installed on company machinery (or third-party machinery where the Association operates), to the detriment of the State, public entities, or EU bodies, to directly and/or indirectly procure an advantage or benefit for the Association.
Every user of IT tools must strictly observe corporate security policies so as not to compromise the functionality and protection of information systems, ensuring the proper use of data acquired during the performance of their duties.
Art. 3.15 Email and Internet Access
Growing reliance on IT technology requires ensuring the availability, security, integrity, and maximum efficiency of Association-related data transmitted or stored electronically.
Every collaborator is therefore required to:
· Refrain from sending threatening or abusive email messages, using obscene or low-level language, or making inappropriate or undesirable comments that could offend individuals and/or damage the corporate image, or that constitute a violation of Association values and policies (such as sexual or racial harassment and other forms of discrimination);
· Avoid spamming or chain letters that generate data/information/process traffic within the company network to an extent that significantly reduces network efficiency and negatively impacts productivity;
· Refrain from browsing websites containing indecent, offensive, pornographic, or otherwise unacceptable content contrary to law and common morality.
Art. 3.16 Traceability and Integrity of Documentation
Each collaborator must maintain adequate documentation for every transaction carried out in accordance with Association procedures, so that the reasons and characteristics of the transaction can be verified at any time across authorization, execution, recording, and verification phases. All documents must accurately and clearly reflect relevant facts and the true nature of each transaction. Any document, in any form, containing incorrect, incomplete, or untrue content is contrary to company policy and will be considered unacceptable.
Art. 3.17 Confidential Information
Maximum confidentiality must be ensured regarding Association documents and information (including projects, proposals, strategies, negotiations, agreements, commitments, pending contracts, and financial projections), in compliance with statutory provisions, applicable regulations, and internal procedures.
Collaborators are required to maintain confidentiality regarding news and/or confidential information obtained from clients, suppliers, competitors, or otherwise available to them by reason of their function. Consequently, they may not disclose such information to competitors of the Ferrara Buskers
Festival Association, to uninvolved third parties (including family and friends), or make improper use of confidential information, unless required by law or judicial authorities.
Finally, disclosing information about the Association to third parties is prohibited unless such information has already been made public.
Art. 4 – Standards of Conduct in Relations with Public Entities and Clients
Compliance with activity programs approved by Contracting Entities and complete client satisfaction represent the main objectives the Ferrara Buskers Festival Association has always chosen to pursue, particularly through establishing solid relationships centered on respect for the core values of fairness, honesty, efficiency, and professionalism.
Art. 4.1 Fairness in Relations with Public Entities and Public Administration in General
All individuals operating in the name and on behalf of the Association toward Public Entities and the Public Administration in general are required to diligently preserve all documentation regarding activities performed, refraining from offering money or any other benefit to interlocutors, or establishing unlawful personal relationships of favor capable of influencing the outcome of the relationship.
The Ferrara Buskers Festival Association maintains good relations with public institutions, both locally and nationally, to understand and evaluate potential implications that legislative and administrative activities might have on the growth and development of the Association. Within these relations, the Association commits to ensuring that untrue applications/requests are not submitted to facilitate the unlawful collection of disbursements, contributions, or financing, or to improperly obtain concessions, authorizations, licenses, or other administrative acts.
Art. 4.2 Relations with Suppliers
In commercial relations established with its suppliers, the Association adheres to the principles of this Code and internal procedures. Indeed, it is the Association’s policy to negotiate in good faith and transparently with all potential suppliers, as well as to avoid even the appearance of engaging in unjustifiably biased negotiations or any logic motivated by favoritism or driven by the certainty or hope of obtaining advantages—even regarding situations unrelated to the supply relationship—for oneself or the Association.
In particular, collaborators involved in relations with suppliers of the Ferrara Buskers Festival Association are required not to exclude anyone possessing the required qualifications from competing for contracts, adopting objective criteria when selecting candidates.
Specifically, collaborators must:
· Scrupulously observe internal procedures relating to the selection and management of supplier relationships;
· Observe and respect applicable legal provisions and contractual conditions in supply relationships;
· Observe principles of transparency and completeness of information in correspondence with suppliers;
· Refrain from receiving money, benefits, or utility from suppliers (or anyone other than the Association) for performing official duties or acts contrary to official duties;
· Refrain from directly or indirectly giving or receiving gifts, courtesy presents, hospitality, or other advantages, except for minor gifts of courtesy or customary gifts used on anniversaries and holidays.
The Ferrara Buskers Festival Association informs key suppliers of the contents of this Code of Ethics through initiatives provided for in its communication plan. Violations of the Code's general principles by suppliers grant the Association the right to trigger express termination clauses inserted into individual supply contracts, alongside specific declarations regarding knowledge of the principles contained in the Code and the commitment to respect them.
Art. 4.2.1 Integrity and Independence in Supplier Relations
Determining purchasing conditions is based on an objective assessment of the quality, price, assistance guarantees, and timeliness of goods or services. Entering into a contract with a supplier must always be based on relationships of extreme clarity, avoiding forms of dependency where possible. In particular:
· Independence from individual suppliers must be pursued, avoiding exclusive and/or long-term relationships unless strictly necessary;
· Supply and consulting contracts not justified by concrete internal needs must be avoided;
· Inducing a supplier to enter into an unfavorable contract by implying a subsequent, more advantageous contract is considered improper.
Art. 4.3 Relations with the Public Administration
Relations between the Ferrara Buskers Festival Association and the Public Administration, or any relations of a public nature, must be guided by strict compliance with applicable legal and regulatory provisions and must in no way compromise the integrity and reputation of the Association.
For the purposes of this Code, "Public Administration" includes, by way of example only, any public entity, independent administrative agency, natural or legal person acting as a public official or public service officer, or as a member of an organ or official of the European Communities or foreign state official. Likewise, under this Code, the definition of public entity includes private entities that, for overriding political-economic reasons, fulfill a public function protecting general interests.
Undertaking commitments and managing relationships of any kind with the Public Administration and/or relationships of a public nature are reserved exclusively to designated and duly authorized organizational units.
In any case, during business negotiations, commercial dealings, or inspections/verifications by competent authorities in Italy or abroad, the Ferrara Buskers Festival Association commits to:
· Not offering employment and/or commercial opportunities to Public Administration personnel involved in negotiations, relationships, or inspections, or to their family members, unless at least two years have passed since the termination of their public status;
· Not offering, directly or through third parties, sums of money, gifts, or benefits of any kind and amount to Public Administration personnel or their family members with whom the Association maintains commercial relations, to compensate them for an official act or to obtain an act contrary to their official duties;
· Not improperly influencing the decision-making autonomy of the institution concerned or officials negotiating or making decisions on its behalf;
· Not soliciting or obtaining confidential information that compromises the integrity or reputation of either party.
During negotiation activities for active or passive public contracts, no collaborator or partner may:
· Exchange information on offers and/or enter into agreements with other participants, even if business partners;
· Send false or artfully drafted documents, certify non-existent requirements, or provide untrue guarantees;
· Direct the content of the offered service to their own benefit and to the detriment of the Public Administration.
Where deemed appropriate, the Ferrara Buskers Festival Association may support public entity programs aimed at creating benefits for the community, as well as the activities of foundations and associations, always in compliance with applicable regulations and the principles of this Code.
If collaborators receive explicit or implicit requests for benefits of any nature from the Public Administration or from natural/legal persons acting under or on behalf of the Public Administration, they must immediately suspend all relations and inform their hierarchical superior.
The above provisions must not be circumvented through alternative forms of aid or contributions (e.g., assignments, consultancies, advertising, sponsorships, representation expenses) that serve purposes similar to those prohibited in this section.
Art. 4.4 Relations with External Collaborators and Consultants
Collaborators in any capacity and external consultants of the Association are required, in executing their contractual relationships or assignments, to act with fairness, good faith, and loyalty, complying with applicable provisions of this Code of Ethics, company regulations, and instructions provided to personnel, under penalty of contract termination. The Association carries out the identification and selection of collaborators and consultants with absolute impartiality, autonomy, and independence of judgment.