Introduction

This Code of Ethics (hereinafter referred to as the "Code") defines the principles to be followed by entities operating with and in the interest of the Glorious Property Holdings Group (hereinafter referred to as the "Group").

Compliance with this code is mandatory.

The Code represents a distinctive and identifying element towards the market and third parties. Anyone who operates, for whatever reason, in the Company or cooperates with it shall know and share this Code.

This Code applies to directors, executives, employees and any collaborator working for the Group, even in positions of out-of-position placement, in position of command, detached or part-time workers, as well as consultants and anyone authorised to attend the Group’s offices for the purpose of carrying out studies or research.

Article 1 – General Principles

1. The conduct of the Recipients is based on the principles of loyalty, integrity and professionalism, confidentiality and diligence.
2. Loyalty. The Group and the Recipients undertake to achieve fair competition, in compliance with national and EU legislation, knowing that virtuous competition is a healthy incentive to innovation and development processes, and also protects the interests of consumers and the community.
3. Integrity. Correctness and moral integrity are an indefectible duty for all Recipients who are obliged not to establish any privileged relationship with third parties, which is the result of external solicitations aimed at obtaining improper advantages.

In carrying out their activities, the Recipients are required not to accept donations, favours or benefits of any kind (except for items of moderate value) and, in general, not to accept any counterpart in order to grant benefits to third parties in an improper way.

At the same time, Recipients shall not make donations of money or goods to third parties or in any case offer unlawful benefits of favours of any kind (except for objects of moderate value or courtesy gifts authorized by the company) in connection with their activities for the benefit of the group.

The inherent conviction to act in the interest of the Group does not exempt the Recipients from the obligation to observe promptly the rules and principles of this Code and the laws of the place where the Group operates.

4. Professionalism. Professionalism means maintaining and continuously improving their professional skills. In order to do so, Recipients shall understand and comply with the internal regulation applicable to their tasks, complete the training initiatives planned by the Group in a timely manner and ensure that they have all the requirements and certifications required by any external regulation in relation to their role. Professionalism is also developed thanks to a stimulating working environment, which values individual skills, inspired by mutual trust and loyalty and based on the respect for the personality and dignity of each person. For this reason, Recipients shall promote a working environment open to exchange and diversity, free from any kind of discrimination and retaliation.
5. Confidentiality. The Group undertakes to ensure the protection and confidentiality of the personal data of the Recipients and Stakeholders, in compliance with all applicable legislation on the protection of personal data.

The Recipients are obliged not to use confidential information, learned through their work, for purposes unrelated to the exercise of such activity, and in any case to always act in compliance with the obligation of confidentiality assumed by the Group towards all Stakeholders.

In particular, the Recipients are bound to the utmost confidentiality on documents suitable for disclosing know-how, transport information, commercial information and corporate transactions.

6. Diligence. The relationship between the Group 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.

Recipients must refrain from any activity that may conflict with the interests of the Group by waiving the pursuit of personal interests in conflict with the legitimate interests of the Company.

In cases where there may be a conflict of interest, the Recipients are required to contact, without delay, their hierarchical superior so that the company can evaluate, and possibly authorize, the potentially conflicting activity.

In cases of infringement, the Company will take all appropriate measures to end the conflict of interest, reserving its own protection.

7. Compliance with the laws. The Recipients of this Code are obliged to avoid any and all acts that violate or may cause violation of the provisions of law and those contained in the Code.
8. Relations between the Group and the recipients of this Code are based on trust and collaboration.
9. 9In relations with the outside world, all employees and collaborators of the Group are obliged to conduct themselves in such a way as to determine trust and collaboration with anyone that come in contact with the Group, showing courtesy and availability in communication with the public and taking care of any issue in an efficient and prompt manner.
10. The Group respects the cultures of the countries in which it operates and intends to contribute, thanks to the entrepreneurial activity carried out, to their economic and social development. Adhering to the ten principles of the Global Compact promoted by the United Nations, the Group shares, supports and applies fundamental principles in the field of human rights, labour standards environmental protection and the fight against corruption and tax evasion, with the aim of creating an economic, social and environmental framework that promotes a healthy and sustainable economy. Recipients shall therefore always consider the economic, social and environmental impacts that their business decisions may have and the consequences that their activities, including personal ones, may have on the name and reputation of the Group.

Article 2 – Recipients Of The Code And Their Obligation

1. The Recipients of this Code are divided into Internal Recipients and External Recipients.
2. Internal Recipients: employees, in command position, secondment or out of position or internal collaborators with any type of contract or assignment and for any reason.
3. External Recipients: collaborators and partners (however called and/ or organized) with any type of contract or assignment and for any reason. In particular, any collaborators of the external Recipients, which the latter make use of in fulfilling their obligations towards the Group, are considered joint and several responsible and must respect this Code.
4. Upon taking up the service or signing the contract or other contract of collaboration or partnership, however called or qualified, the Recipients of the Code undertake to comply with the rules of this Code.
5. Recipients carry out their tasks in compliance with the law, pursuing the interests of the Group, without abusing the position or powers of which they are holders, while also respecting the principles of integrity, fairness, good faith, proportionality, objectivity, transparency, fairness and reasonableness.
6. Recipients undertake to act and assume a position of independence and impartiality, abstaining in the event of a conflict of interest. They shall carry out their tasks by directing their work towards maximum cost-effectiveness, efficiency, efficiency and transparency. 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 shall not in any way affect the quality of the results.
7. Recipients carry out their work with the commitment necessary for the successful performance of their tasks. Their behaviour is based on the maximum cooperation between the parties involved in any way in the Group’s activities.
8. Recipients shall report to their manager any event in which they have been directly involved and which may have repercussions on the service or that is related to situations of danger or damage to physical or psychological integrity for them or for others or to the risk of non-compliance with the Code and/or the laws of the place where the group operates.
9. Recipients shall also undertake to respect the communications and directives of company managers and any other internal act applicable to them directed to the regulation of the employment relationship or collaboration in any capacity and to the organization of the office where they work including written and oral orders of the manager responsible of their department.

Article 3 - Behavioural Obligations Towards Internal And External Users

1. The Recipients ensure listening to the needs and requirements of stakeholders, adopting a behaviour based on legality, professionalism, competence, promptness, courtesy, transparency of their work, fairness and impartiality.
2. The Recipients act in compliance with the applicable laws of the place where the Group operates, contributing to the achievement of the assigned task, without being influenced by political forces, pressure groups or anyone attempting to influence their actions, they carry out their tasks 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 the interlocutor.
3. Recipients shall not accept, nor make for themselves or for others, reports, solicitations in any case directed to affect the normal course of activities and refrain from soliciting external or internal recommendations to secure personal or social privileges on their job (even outside the working environment). 
4. In their relations with colleagues, collaborators and partners, the Recipients of the Code constantly ensure maximum collaboration, respecting each other’s positions and institutional responsibilities; they avoid attitudes and behaviours that may disturb the necessary climate of serenity and harmony within the offices; they refrain from behaviours that may damage the image and sensitivity of another employee, including through the circulation of information relating to the private sphere of the person, not relevant, therefore, to the service performed by the latter for the Group.
5. Subject to the rules of professional secrecy and to the extent provided for by the law of the place where the Group operates, Recipients of the Code shall not use confidential information that they have become aware of in the exercise of their work. In particular, the disclosure to third parties of information on decisions to be taken and measures relating to ongoing proceedings before they have been officially decided upon shall be prohibited. The staff, including managers, who, on behalf of the Group, maintain relations with other subjects, including institutional ones, are obliged not to report and not to use, outside the mandate of representation received, the information acquired as a result of such relations. Recipients shall refrain from making public statements that could harm the Group. The Recipients who participate in public meetings, publish writings or give interviews on subjects that concern the Group, indicating their belonging to the Group. In the absence of a specific mandate, they are required to inform the Group in advance and to specify that the opinions expressed are of a personal nature. Where the content of the written text or of the intervention has a high resonance in public opinion and is of strategic importance and has a strong impact, the text to be published or disclosed must be submitted to the Group for its attention.

Article 4 - Prevention Of Corruption

1. Managers shall ensure that their employees comply with the measures necessary for the prevention of offences.
2. All employees cooperate with the corruption prevention manager by reporting, via their hierarchical superior: a) any difficulties encountered in complying with the requirements of the laws where the Group operates; b) the direct detection of additional risk situations not specifically regulated in the abovementioned national legislation.
3. The Recipients of the Code, without prejudice to the obligation to report to the Judicial Authority, Supervision and/or Guarantee (the latter if and when provided), report to the responsible manager any illegal situations within the Group that has come to their knowledge.
4. The responsible manager of the employee who has denounced and/or reported illicit situations in the Group or in the actions of the internal or external recipients of the Group’s social structure shall verify the accuracy and truthfulness of the information learned by taking any action to protect the interests and reputation of the Group and its employees, collaborators and institutional Partners that it uses in the exercise of its activities.
5. In disciplinary proceedings, the identity of the reporter may not be disclosed without his or her consent, provided that the claim of the disciplinary charge is based on separate and additional findings in relation to the report, that the Group has the burden of undertaking.
6. The Group acquires and maintains its business relationships exclusively on the basis of its excellent service offering and the specific needs of the customer refusing any conduct which is or may appear to be aimed at obtaining or offering improper advantages.
7. Recipients are required to: a) not to offer or promise, even indirectly, money or other benefits to obtain an improper or unfair advantage; b) not to accept money or other benefits to violate their duties towards the Group.
8. The notion of other benefits includes any good that has value, invitations, donations, gifts, travel/accommodation expenses, fees, employment opportunities, collaboration or internship.
9. Facilitation payments, made to speed up the completion of an administrative process, without affecting its outcome, are also prohibited.
10. The control of corruption risks is also ensured within the processes of adequate verification and selection of the Group’s employees.
11. In particular, in order to avoid indirect involvement in any illegal acts committed by third parties distinct from the Group, the selection of brokers, Stakeholders and agents provides for the reputational analysis of these subjects.
12. Lastly, in the structuring and conduct of operations and when concluding commercial agreements, the Recipients are required to assess the potential legal and reputational risks related to corruption, also taking into account the reputation and the country of establishment of all relevant subjects.
13. Gift exchange on particular occasions is a common practice, which can strengthen or provide added value to business relationships. Gifts which, by reason of their characteristics or methods, may appear to be made in order to improperly influence the independence of judgment and conduct of the parties involved should be avoided, exposing the Group to the risk of violation of the applicable legislation on corruption.
14. Specific internal authorization processes are provided with reference to gifts that exceed certain value thresholds or that could present compliance profiles following self-assessment tests.
15. Particular attention must be paid in particular to gifts from internal collaborators to public entities.

Article 5 - Relationship With Clients

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.
2. Recipients must provide potential customers with clear, correct and comprehensive information about the products and services offered, so that the customer can make informed decisions. Therefore, the Recipients must know in depth the products and services that can be offered. The information, to be provided in good time with respect to 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. 
3. The information contained in the reference documentation must be delivered well in advance of the signing of the contract, so that the customer can make an informed decision, comparing several alternatives.
4. The Recipients must not provide information that does not correspond to the true or capable of deceiving potential customers about the characteristics of the product/service. 
5. In dealing with Customers, Recipients must use official channels and specifically the email provided to them by the Group on the domain @creditglorious.com.
6. In dealing with Customers via email, Recipients must keep in the signature all the data of the Group that the latter will provide and in the way indicated and this also in order to strengthen the credibility of the collaborator and the relationship between the same and the Group.
7. The Recipients must know in depth the characteristics of the customers and the objectives, short and long term, they pursue, in order to always offer the best services and products to meet them. The Recipients must also respect the reference market and distribution strategy defined at the time of creation. In no case shall the Recipients offer products or services that are not adequate for their customers.
8. When advising clients, the Recipients must collect and evaluate sufficient information to provide recommendations appropriate to the specific knowledge and experience of the 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 customer.
9. The protection of the customer’s best interests must not be sacrificed in order to achieve a higher economic return.
10. During the relationship with a client, the Recipients must be available to respond clearly and promptly to any requests for clarification or further information from customers on the products/services purchased. If a customer is not satisfied with the product/service and makes a complaint, even informal, the Recipients must immediately inform the Group and follow any instructions received. Complaints will be handled with sensitivity and professionalism, considering them an opportunity to improve and increase the trust and satisfaction of customers.
11. The Recipients must exercise every possible control to ensure that suppliers and customers are also able to respect the fundamental ethical principles set out in this Code.

 

Article 6 - Relations With External Parties

1. Recipients do 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 permission or subsequent ratification by the Group, shall be deemed to be assumed personally by the Recipient, without any consequence for the Group.

2. Relations with the Judicial Authority, the Guarantee and Supervisory Authorities and Public Entities must be marked by maximum clarity, transparency and collaboration, in full respect of the law and according to the highest moral and professional standards.
3. Recipients, subject to express permission, shall not relate in the name and on behalf of the Group with the subjects indicated in paragraph 1.
4. In their relations with the subjects referred to in paragraph 1, the Authorised Recipients comply with the highest levels of correctness and integrity, refraining from any form of pressure, explicit or veiled, aimed at obtaining any undue advantage for themselves or for the Group. In this regard, the authorized Recipients will be required to strictly observe the provisions of this Code, as well as, more generally, the directives issued by the Group’s management. management del Gruppo.
5. Recipients are required to refrain from any direct, indirect or purported pressure on politicians or trade union representatives.
6. 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.
7. 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 7 - Reputational Risk Management

1. The excellent reputation of the Group, based on respect for its core values, is an extremely valuable asset, to be defended as any damage could have lasting consequences that are difficult to fix. To this end, the Recipients must always consider the impact of their behaviour on the Group’s reputation, also on the basis of the risks associated with customers, counterparties and specific transactions.
2. In the course of the report, Recipients are also required to promptly communicate to the Group all updated customer information that could have a reputational impact on the Group.
3. Recipients must pay close attention to the expressions contained in communications and documents, including internal documents.
4. Recipients must avoid all behaviours that could call into question their integrity and honesty, even outside of work because they can have an impact on the Group’s reputation. Customers, counterparties and the public can perceive, in fact, the Recipients as representatives of the Group even when they are not carrying out their work.
5. Recipients must immediately inform the Group if they are aware of or are involved in an event that may involve a reputational risk for the Group and comply with any instructions received. The notification is required, in particular, if a Recipient, with reference to the activity carried out in favour of the Group: a) is involved in judicial or sanction proceedings; b) is involved in an investigation, inspection or request of the authority; c) receives a complaint from a customer or a third party.

 

Article 8 - Powers Of The Group And Sanction System

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.
2. If the Group has a well-founded doubt, also inferred from the documentation in its possession and/or from the attitude or behaviour 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 and take any appropriate action, including informing the Judicial Authority, to protect its interests and reputation.
3. The conduct in violation of the Code constitute: a) or serious non-fulfilment for employees (employees and managers), with penalties, applied depending on the severity (verbal reprimand, written reprimand, fine not exceeding three hours of pay, suspension of work and pay for up to three working days, dismissal for good cause or justified reason); in the case of pending prosecution or the enforcement of a measure restricting the employee’s personal freedom before taking disciplinary action, the sanction of suspension from service and remuneration may be adopted, for the duration corresponding to the outcome of the prosecution or until the end of the duration of the measure restricting personal liberty b) due cause for revocation of the mandate of the directors; c) or cause of immediate termination of the relationship, in the most serious cases, for external and parasubordinate collaborators; d) or cause of immediate termination of the relationship, in the most serious cases, for the suppliers, contractors and subcontractors.
4. For the violation of one or more rules of this Code, the External Recipients are subject to the following sanctions: if Partner or other entity otherwise named and bound by a contract of collaboration with the Group, the latter, at its discretion, may reduce proportionately the remuneration due, from a minimum of 10% to a maximum of 50% in the case of slight negligence; if, on the contrary, it is a matter of wilful misconduct or gross negligence, it can immediately terminate the contract, reducing by 100% the compensation due to the collaborator. 
5. In any case, the Group reserves the right to exercise all the actions it deems appropriate for the compensation of the damage suffered as a result of the behavior in violation of this Code and national regulations.