Article 1 : Sphere of applications and Recipients

1. The principles and provisions of this Ethic Commitment (hereinafter "Commitment") represent exemplary specifications of the general obligations of diligence, correctness and loyalty qualifying the fulfilment of the work services and behaviour in the work environment.
2. The principles and provisions of the Commitment are binding for the directors of ebilling S.p.A. ("Directors"), for all persons tied by subordinate labour contracts to ebilling S.p.A. ("Employees") and for all those who work for ebilling S.p.A., whatever the work relationship, including temporary, and who are tied to the company ("Associates"). The Directors, Employees and Associates are hereinafter jointly called "Recipients".
3. The Commitment shall be made known to third parties appointed by ebilling S.p.A. or who have stable or temporary relations with the company as well as, with specific reference to external associates, in order to comply with relevant contractual agreements.

Article 2 : Notification

1. ebilling S.p.A. informs all Recipients of the provisions and application of the Commitment and asks for these to be observed.
2. The Recipients, including in compliance with applicable laws, must refrain from behaving in any way contrary to the provisions contained in the Commitment and must promptly report to whosoever it may concern the receipt of the following information:
   1. any reports concerning the infringement or possible infringement of the provisions of the Commitment;
   2. any request to infringe the Commitment made to them.

Article 3 : Liability

1. Each recipient shall perform its business activity and provide its services diligently, efficiently and precisely, using in the best possible way the instruments and the time at his/her disposal and shouldering all liability as regards the operations to be performed, in accordance with applicable laws, as well as with the procedures and duties established by ebilling S.p.A..

Any infringements of the ethic commitment by Employees shall represent the non-fulfilment of the obligations relating to their employment and shall be considered as irregular behaviour and as such they shall be subject to the sanctions laid down by the law and the Collective National Labour Contract, with all legal consequences, including the discontinuation of the employment (and this quite apart from the penal importance of the behaviour in question and/or the starting of criminal proceedings in the event of an offence having been committed).

In the event of the Ethic Commitment being infringed by an Associate, such behaviour shall be sanctioned in conformity with the provisions of the relevant contractual agreements, for example through the determination of the contract.

In the event of the Ethics Commitment being infringed by one or more members of the Board of Directors, said infringement shall be assessed according to its seriousness and, in the most serious cases, could result in the revocation of the appointment as provided by the law.

Article 4 : Fairness

1. All the actions and operations performed and the behaviour of each of the Recipients in the fulfilment of their appointments or duties, shall be inspired by formal and substantial legitimacy according to applicable laws and internal procedures, as well as by fairness, cooperation, loyalty and mutual respect.
2. The Recipients shall not use information, goods and equipment of which they avail themselves during the performance of their duties or the appointment for personal purposes.
3. The Recipients shall diligently observe applicable laws, the Ethic Commitment and internal regulations. Under no circumstances shall the pursuit of ebilling S.p.A. interests justify dishonest conduct or conduct not in conformity with applicable rules.
4. ebilling S.p.A. Employees shall abstain from performing activities in competition with those of ebilling S.p.A. and shall observe company rules and comply with the principles of this Commitment, the observance of which is also required pursuant to and by effect of art. 2104* of the Italian Civil Code.
5. Recipients shall not, on its own behalf or that of others, bring pressure to bear, or make recommendations or notifications that could negatively affect ebilling S.p.A. or bring undue advantages to themselves, to ebilling S.p.A. or to third parties; each Recipient, shall furthermore reject and not make promises and/or undue offers of money or other benefits, unless the latter are of low value and not related to requests of any kind.
6. In the event of the Recipient receiving an offer or a request for benefits from a third party, excepting normal commercial gifts or of low value, it shall not accept said offer, nor comply with said request and shall immediately inform its hierarchic superior or the person to whom it is obliged to refer to in such cases.

Article 5 : Conflicting interests

1. The Recipients shall pursue, in the performance of their activities and/or appointments, the objectives and general interests of ebilling S.p.A., in compliance with applicable laws and this Commitment.
2. The Recipients shall promptly inform their superiors or contacts of situations or activities in which they could hold interests in conflict with those of ebilling S.p.A. (or if such interests are held by near relations) and in all other cases in which reasons of convenience exist. The Recipients shall abide by the decisions taken in this respect by ebilling S.p.A. and shall abstain in any case from performing operations in conflict of interests.

Article 6 : Confidentiality

1. The Recipients shall provide utmost confidentiality regarding news and information relating to company assets or ebilling S.p.A. activities, in compliance with legal provisions, applicable regulations, this Commitment and internal procedures.

Article 7 : Business relations

1. During the course of its business relations ebilling S.p.A. follows principles of legality, loyalty, correct behaviour, transparency and efficiency.
2. ebilling S.p.A. Employees and Associates, whose actions are in any way referable to ebilling S.p.A. , shall behave correctly in the business relations of interest to ebilling S.p.A. and, more specifically, in relations with the Public Administration, whatever the competitiveness of the market or the importance of the business transaction, and shall abstain from implementing, legitimating, accepting or favouring behaviour that is not strictly in conformity with applicable laws and the principles of correct behaviour, diligence and loyalty of this Commitment.

Article 8 : Client relations

1. ebilling S.p.A. pursues its company success on markets through the offer of quality products and services at competitive conditions and in compliance with the rules protecting against unfair competition.
2. ebilling S.p.A. acknowledges that the appreciation of persons requiring products and services is of primary importance for its success as a company. ebilling S.p.A. therefore undertakes to:
   observe the internal procedures for the management of relations with clients; to provide, with efficiency and courtesy, within the limits of contractual provisions, top-quality products that satisfy or exceed the reasonable expectations of the client;
   to provide accurate and exhaustive information on the products and services so that the client can take mindful decisions;
   to always be truthful when advertising or in any other circumstance.

Article 9 : Supplier relations

1. The selection of suppliers and the determination of the purchasing conditions are based on an objective evaluation of the quality and price of the goods or service and on assurances relating to assistance and promptness.
2. In its supply relations, ebilling S.p.A. undertakes to:
   observe internal procedures for the selection and management of supplier relations;
   not preclude any supplier in possession of the necessary requirements from running to compete for an ebilling S.p.A. tender, adopting in its selection objective evaluation criteria, in accordance with certified and transparent procedures;
   to obtain the cooperation of suppliers in constantly catering for the requirements of ebilling S.p.A. clients in terms of quality, costs and delivery times at levels at least equal to their expectations;
   to maintain a frank and open dialogue with suppliers, consistent with good business practices.

Article 10 : Relations with institutions

1. ebilling S.p.A. and Recipient relations with local, national, community and international public institutions (?Institutions?), as well as with public officials or public service representatives, meaning bodies, representatives, agents, exponents, members, employees, consultants, persons appointed to carry our public functions, with public institutions, including economic, with public companies or institutions of a local, national or international nature (?Public Officials?) shall be maintained by each Director and each Employee, whatever his/her function or appointment, or, by each Associate, in compliance with applicable laws and according to general principles of correct behaviour and loyalty.
2. In the specific case of a Public Administration tender, ebilling S.p.A. and the Recipients shall operate in accordance with the law and correct business practices.
3. ebilling S.p.A. shall never be represented in its relations with Institutions or Public Officials, by Employees or Associates with whom conflicts of interest could arise.
4. Without prejudice to all the obligations laid down by applicable laws, ebilling S.p.A. and the Recipients shall abstain, during the course of business negotiations, requests or business relations with Institutions or Public Officials, from undertaking the following actions (directly or indirectly):
   1. examining and suggesting opportunities for use and/or sale that could benefit employees of the Institutions or Public Officials, on own account;
   2. offering or in any way supplying, accepting or encouraging gifts, favours or sales or behavioural practices not distinguished by the utmost transparency, correctness and loyalty and, in any case, which are not in conformity with applicable laws;
   3. asking for or obtaining confidential information that could affect the integrity or reputation of both parties or which, in any case, infringe the equal treatment and public procedures implemented by the Institutions or Public Officials.
5. ebilling S.p.A., whenever it considers it opportune, shall be entitled to support programmes of public bodies aimed at achieving advantages and benefits for the community, as well as the activities of foundations and associations, always in compliance with applicable laws and the principles of the Commitment.

Article 11 : Protection of safety and health

1. ebilling S.p.A. activities are inspired by the principle of safeguarding the environment and pursuing the goal of protecting the safety and the health of the Recipients
2. ebilling S.p.A. activities shall be managed in compliance with the applicable laws on prevention and protection.

Article 12 : Accountancy control and transparency

1. The Recipients undertake, in conformity with their respective functions and duties, to ensure that the facts relating to company management are represented in a correct and truthful manner in ebilling S.p.A. accounts.
2. The documents certifying accountancy recording activities must be such as to ensure prompt reconstruction of accountancy operations, the finding of any errors, and the degree of responsibility within the single operating process.
3. Always within their respective functions and duties, the Recipients shall be obliged to check the correctness and truthfulness of the accountancy recordings and make known, to whosoever it may concern, any errors, omissions and/or falsifications of such recordings.

Article 13 : Acceptable use policy of company information systems

The gradual spreading of new information technologies and, especially, free access to the Internet on the part of Personal Computers, exposes eBilling to the risks of both patrimonial and penal involvement, creating problems for Company security and image. Considering therefore that the use of the Company?s information technology and telematic resources must always be inspired by the principle of diligence and correctness ? behaviours normally adopted in a work relationship - eBilling has adopted this Acceptable use policy of company information systems
which represents an internal regulation aimed at avoiding unaware forms of behaviour that could trigger problems or threats to security as regards data processing.

This regulation contains the rules of behaviour concerning:

1. the use of electronic computer tools
2. data processing on paper medium

which all eBilling employees must be acquainted and comply with.

These rules are adopted in compliance with the internal eBilling regulations and the regulations on the protection of personal data (Commitment regarding the protection of personal data approved by Law Decree no. 196/03, subsequently indicated with Law Decree no.196/03).

It should be remembered that, generally speaking, complying with the provisions regarding the protection of personal data indicated in the letter of appointment of the Person charged with data processing pursuant to Law Decree no. 196/03 is mandatory.

This regulation is at the disposal of all partners who have institutional or commercial relations with ebilling S.p.A. in order to ensure the best security conditions required to perform the above activities in the best possible way.