This code of conduct (hereinafter referred as to the “Code”) defines the rules of conduct in order to guarantee the necessary transparency and correctness between the Glorious Property Holdings group (hereinafter referred as to the “Group”) and the subjects that come in contact with it.
The Group respects the Code in each and every of its activities all over the world.
This Code shall be considered binding and not exhaustive.
Anyone can find the Code in e-format on the Group’s website and can address a request for a paper copy to the Management.
Article 1 – General Principles
1.1. Respect for inviolable human right is essential. Therefore, the Group promotes and defends these rights in any circumstances and repudiates any discrimination based on sex, ethnicity, language, religious and political beliefs and social and personal conditions. The Group embodies the principles set out in the Universal Declaration of Human Rights, the UN Convention on the Rights of the Child and Adolescents, the International Labour Organization and the OECD Guidelines for Multinational Enterprises.
1.2. The Groups respects any law and, in general, any local, national or international regulation applicable in any country in which the Group operates.
1.3. The Group carries out all economic transactions and financial transactions in accordance with the principles of integrity and transparency.
1.4. The Group rejects corruption as a means of conducting its business.
1.5. The Group recognises that fair competition is a fundamental element for the development of business. Therefore, the Group respects the applicable antitrust law and the rules of fair competition and in no case is shall engages in any act or conduct contrary to free and fair competition.
1.6. The conduct of the Group’s employees and collaborators, in any capacity, is based on the principles of loyalty, integrity and professionalism, confidentiality and diligence, as best specified in the Code of Ethics adopted by the Group.
ARTICLE 2 – RELATIONS BETWEEN THE GROUP AND THE CLIENTS
2.1. The Group considers as its own clients anyone who buys its products and/or services or uses them.
2.2. The Group guarantees equal treatment to its own current and potential clients. For this purpose, the Group does not discriminate among the clients without objective and verifiable reasons.
2.3. The Group imprints its relationships with customers on listening, availability, courtesy, honesty, loyalty, professionalism and, in any case, respect for the general principles of this Code of Conduct
2.4. Customer satisfaction is a primary resource. For this reason, the Group puts in place measures and procedures to verify and evaluate that clients are satisfied with the products and services offered, so as to continuously improve the level of its commercial offer and to be able to quickly and effectively remedy cases of possible dissatisfaction.
2.5. The Group takes necessary measures to ensure that all the processes comply with the applicable law or regulation and, in any case, with the confidentiality of that data and information.
2.6. All communication to clients shall be truthful, correct and fair.
2.7. The Group shall have the right to ask the Customers, who in turn shall be required to provide it, all the information necessary for compliance with the anti-money laundering legislation.
ARTICLE 3 – RELATION BETWEEN THE GROUP AND EMPLOYEES/COLLABORATORS
3.1. all those who maintain, in the forms provided for by law, a working relationship or collaboration with the Group, aimed at achieving the objectives of the company shall be considered employees or collaborators of the Group. Managers, permanent, fixed-term and temporary employees, part-time employees, occasional collaborators, project collaborators shall be considered employees or collaborator of the Group.
3.2. The Group rejects, first of all within itself, any discrimination among employees and collaborators based on sex, ethnicity, language, religious and political beliefs and social and personal conditions. It promotes a working environment where the dignity of each individual is guaranteed and the relationships between people take place based on the principles of respect, fairness and collaboration. The Group also takes care to avoid stress and, in general, work discomfort, including by means of monitoring and communication tools. persone si svolgono su una base di rispetto, correttezza e collaborazione. Il Gruppo, inoltre, si cura di evitare lo stress e, in generale, il disagio lavorativo, anche mediante controlli e strumenti di comunicazione
3.3. The Group encourages and promotes equal opportunities for women and men.
3.4. The Group values the skills, potential and commitment of each of its employees and collaborators: to do this, it adopts clear and homogeneous evaluation criteria and provides adequate training.
3.5. No abuse of authority is tolerable in employment and cooperation relations. Therefore, the hierarchical superiors, towards any subordinate, cannot perform any act or conduct that is not provided for by law or by applicable collective and individual agreements.
3.6. The Group endeavour to encourage and involve everyone in the pursuit of business objectives and in the solution of problems on the basis of their respective skills and responsibilities. For this purpose, organisational clarity and transparency are a fundamental tool.
3.7. The relationship between Credit Glorious and its employees is based on mutual trust: employees are, therefore, required to work to promote the interests of the company, respecting the values set out in this Code, as well as the Code of Ethics adopted by the Group.
3.8 .Directors, employees and collaborators pursue the objectives and general interests of the Group in carrying out the relation. They shall inform without delay, taking into account the circumstances, their superiors or contact persons of situations or activities in which they may have interests in that are in conflict with those of the Group (or where such interests are held by close relatives) and in any other case where there are significant reasons for convenience. Directors, employees and collaborators respect the decisions taken by the Group in this regard.
3.9. Directors, employees and collaborators ensure the utmost confidentiality with regard to news and information constituting company assets or relating to the Group’s activities, in compliance with the provisions of law, current regulations and internal procedures.
3.10. Directors, employees and collaborators carry out their work and their performance with diligence, efficiency and fairness: in doing so, they make the most of the tools and time available to them and assume the responsibilities related to the fulfilment. They shall not use for personal purposes any information, assets and equipment given to them to perform their job or duties
ARTICLE 4 - DUTIES OF EMPLOYEES AND COLLABORATORS OF THE GROUP
4.1. In the external relations, all employees and collaborator shall maintain a conduct that gives trust to those who come in contact with the Group, showing courtesy and availability in the communications with the public and taking care of any issue in an efficient and prompt manner.
4.2. Employees and collaborators shall carry out their duties according to the law, pursuing the interests of the Group without abusing of their position or power and respecting, moreover, the principles of integrity, correctness, good faith, proportionality, objectivity, transparency, fairness and reasonableness.
4.3. I Employees and collaborators shall undertake to act and to maintain an independent and impartial position, abstaining in the event of a conflict of interest. They shall carry out their tasks in such a way that they are as cost-effective, efficient, effective and transparent as possible. The management of social resources for the purpose of carrying out the activity they hold or have been entrusted with, must follow a logic of cost containment, which does not in any way affect the quality of the results.
4.4. Employees and collaborators of the Group shall not use any confidential information, acquired in performing their duties, for purposes unrelated to the exercise of that activity, and they shall always respect the Group’s confidentiality obligations towards clients and, in general, all stakeholders.
4.5. Employees and collaborators of the Group shall abstain from any activity that that may conflict with Credit Glorious’s interests and they shall wave the pursuit of personal interests that conflict with the Group’s legitimate interests.
4.6. In cases where it may be the possibility of a conflict of interest, the Recipients are required to contact the Group without delay so that the company can evaluate, and possibly authorize, the potentially conflicting activity.
In cases of violation, the Group shall take all appropriate measures to end the conflict of interest, reserving to act for the protection of its rights.
4.7. The employees and collaborators of the Group carry out their work with the commitment necessary for the successful completion of their duties. Their behavior is based on maximum collaboration between the parties involved in any capacity whatsoever in the Group's business
4.8. Employees and collaborators shall notify their manager or contact person of any event any event in which they have been directly involved and which may have repercussions on the service or on situations of danger or damage to the physical or psychological integrity of their own or others or on the risk of non-compliance with the Code of Ethics and Conduct and the law of the place where the Group operates.
4.9. Employees and collaborators of the Group shall ensure the listening of the needs and requirements of stakeholders, adopting behaviours based on legality, professionalism, competence, promptness, courtesy, transparency of their work, fairness and impartiality.
4.10. Employees and collaborators shall act respecting the applicable laws of the place where the Group operates, contributing to the achievement of the assigned task and avoiding any conditioning from political forces pressure groups or anyone attempting to influence their work. They shall perform their duties in the social interest of the Group and avoid any discrimination based on sex, race or ethnicity, nationality, age, political opinions, religious beliefs or state of health of their interlocutor.
4.11. Employees and collaborators of the Group shall not accept, or perform for themselves or for others, alerts, solicitations in any case aimed at influencing the normal conduct of activities and refrain from soliciting external or internal recommendations aimed at securing privileges in the workplace, personal or social (even outside the working environment).
4.12. The employees and collaborators of the Group shall not have the power to bind the Group and act in the name and on behalf of the Group, unless expressly authorized in writing.
Any liability assumed by a Recipient in the name and on behalf of the Group, in the absence of prior written authorization or subsequent ratification by the Group, shall be deemed to be personally assumed by the employee or collaborator in question, without any consequences for the Group.
4.13. Employees and collaborator of the Group shall not, if not expressly authorized, shall not interact with people outside the Group, in the name and on behalf of the Group itself.
4.14. In their relations with parties outside the Group, authorised Group employees and collaborators shall adhere to the highest standards of correctness and integrity, refraining from any form of pressure, explicit or veiled, aimed at obtaining any undue advantage for itself or for the Group.
4.15. Recipients are required to refrain from any direct, indirect or purported pressure on politicians or trade union representatives.
4.16. The Recipients deal with third parties with courtesy, competence and professionalism, in the conviction that their conduct depends on the protection of the Group’s image and reputation and consequently on the achievement of the company’s objectives.
4.17. In particular, Recipients must refrain from any form of unfair or misleading behaviour that may lead third parties outside the Group to rely on unfounded facts or circumstances.
ARTICLE 5 – RELATIONS BETWEEN EMPLOYEES AND COLLABORATOR OF THE GROUP AND CLIENTS
5.1. The Group earns the trust of Clients by aiming to protect their best interests in the medium and long term and trying to anticipate their needs with an offer of excellent products and services. All customer relations are conducted according to the general principles of diligence, fairness and professionalism.
5.2. Employees and collaborators of the Group shall give clear, correct and complete information to potential clients regarding the products and services offered by the group, for the Client to make informed and mindful choices. Therefore, employees and collaborators of the Group shall have an in-depth knowledge of the products and services offered. The information, to be provided well in advance of the conclusion of the contract, must allow the customer to clearly understand the characteristics of the product and/or service, the risk, the price and its components, the expected performance and the obligations deriving from the Code of Conduct adopted by the Group.
5.3. The information contained in the reference documentation must be delivered by the Group’s employees and collaborators well in advance of the signing of the contract, so that the client can make an informed and mindful decision, comparing several alternatives.
5.4. Employees and collaborators of the Group shall not provide information that do not correspond to the true or that are capable of deceiving potential customers about the characteristics of the product/service.
5.5. When dealing with Clients, Group employees and collaborators shall only use the official channels and, specifically, the email provided to them by the Group on the domain @creditglorious.com.
5.6. When dealing with Clients via email, the Group’s employees and collaborators shall keep in their signatures all the Group’s data that the Group will provide and in the way the Group will ask them to, and this also in order to strengthen the credibility of the collaborator, and the relationship between it and the Group.
5.7. Employees and collaborators of the Group shall have an in-depth knowledge of the characteristics of each client and their short and long term aims they pursue in order to be able to offer them the best products and services to satisfy their needs. Employees and collaborators of the Group shall also respect the market and distribution strategy defined at the time of conception. In no case shall the employees and collaborators of the Group offer products or services that are not adequate for their clients.
5.8. When advising clients, Group employees and collaborators must collect and evaluate sufficient information to provide appropriate recommendations with respect to the specific knowledge and experience of clients, their financial situation (including the ability to bear losses and risk tolerance) and their investment objectives. In any case, it is not possible to recommend inappropriate operations to the client.
5.9. The protection of the customer’s best interests must not be sacrificed in order to achieve a higher economic return.
5.10. during the relations with the client, employees and collaborators of the Group shall be available to answer clearly and promptly to any request for clarification or information regarding products and services purchased. If a client is not satisfied with the product/service and makes a complaint, even informal, the employees and collaborators of the Group shall immediately inform the Group and shall follow any instructions received from it. Complaints will be handled with sensitivity and professionalism, considering them an opportunity to improve and increase the trust and satisfaction of clients.
5.11. Employees and collaborators of the Group shall exercise every possible control to ensure that their potential collaborators also respect the fundamental ethical principles set out in this Code, as well as the Code of Ethics adopted by the Group.
ARTICLE 6 - POWER OF THE GROUP AND SANCTIONING REGIME
6.1. The internal control system is oriented towards the adoption of tools and methodologies aimed at counteracting potential business risks, in order to ensure compliance not only with laws, but also with internal provisions and procedures. In fact, the violation of the principles set out in the Code and in the procedures indicated in the internal controls compromises the fiduciary relationship between the Group and its directors, employees, consultants, collaborators in various ways, customers, suppliers. These violations will therefore be immediately prosecuted by the Group in an effective and timely manner, through the adoption of appropriate and proportionate disciplinary measures.
6.2. If the Group has a well-founded doubt, also inferred from the documentation in its possession and/or from the attitude or behavior of one of the Recipients, that its own manager, internal and/or external collaborator, partner is involved or may be involved in any illegal activity the Group has the right to immediately withdraw from the contract, terminate all relationships with the Recipients and take any appropriate action, including informing the Judicial Authority, to protect its interests and reputation.
6.3. Should the Group find information or documents in its possession provided by the Client and bearing false or untrue statements or any illegal activity towards the company and or third parties, the Group shall have the right to terminate immediately the contract(s) and all relationships with the party who provided the documents or engaged in illegal activity, deducting the sums received to cover the costs incurred for the activity carried out and as compensation for the damage suffered. In any case, the Group reserves the right to exercise all the actions it deems appropriate for the possible compensation of the further damage suffered as a result of the behavior in violation of this Code and national regulations.
6.4. If the Client does not provide the Group with all the data and information requested by the latter also for the purposes of anti-money laundering, the Group shall have the right to immediately terminate the contract concluded with the client, by deducting the sums received to cover the costs incurred for the activity carried out and as compensation for the damage suffered. In any case, the Group reserves the right to exercise all the actions it deems appropriate for the possible compensation of the further damage suffered as a result of the behavior in violation of this Code and national regulations.