Acting with integrity
Welcome to the Eurisko S.r.l. Code of Business Ethics.
At Eurisko, our daily commitment is to do the right thing. Since we began building this firm in 2002, we have shown that it is possible to grow by delivering real value to our clients, real opportunities to our people, and by staying faithful to a high ethical standard.
We are an organisational and technology consulting firm: our work enters our clients' most sensitive processes, accompanies their transformations, and touches their data and strategic decisions. For this reason, integrity is not an abstract value to us, but an operational condition: it is what allows clients to entrust us with their business, colleagues to trust one another, and ourselves to look with pride at the work we do.
This Code exists to translate our principles — vision, goal, method — into concrete behaviours. It does not replace common sense, but guides it. It does not eliminate difficult situations, but provides a shared framework to address them. We ask you to read it carefully, make it your own, and above all apply it: in your relationships with colleagues, with clients, with suppliers, and with the communities in which we live and work.
Our Code is more than a document. It is what we believe in, it is the way we work, it is the way we want to be recognised in the market. It is the concrete expression of our philosophy: thinking outside the box and treating others with the same respect you would expect to receive.
The Management — Eurisko S.r.l.
Our Code of Business Ethics
Our Code of Business Ethics is grounded in our values, provides extensive detail on expected behaviours, and guides our culture of compliance, ethical conduct and accountability. The Code begins with a simple statement: we always act with integrity and in compliance with the law. Beyond being the right thing to do and protecting Eurisko, acting with integrity improves our performance, reflects our personality as a firm, and enables us to attract and retain the best talents and the best clients.
The three pillars — Vision · Goal · Method
- Vision — We anticipate signals of change in the market and react promptly, walking alongside the client in every need and opportunity for development.
- Goal — We provide the client with what is needed to run the core of their business, proposing tailored solutions grounded in real business processes.
- Method — Through motivated professionals with deep product knowledge, we guide the client by defining together the most efficient path to the goal.
The four promises — One way of working
- We are agile and innovative — We adapt quickly to change and bring pragmatic innovation to every project.
- We are customer centric — The client is at the centre: every technical and methodological choice stems from real business needs.
- We care for the future — We build solutions that last, mindful of people and the evolution of technology.
- We win together — We work as one team with the client: project success is a shared result.
Regulatory framework of reference
This Code operates within the Italian and European regulatory framework applicable to Eurisko's activities. In particular, it forms an integral part and a precondition of the Organisation, Management and Control Model adopted pursuant to Italian Legislative Decree 231/2001 (administrative liability of legal entities). The Code also incorporates the principles of personal data protection legislation (EU Regulation 2016/679 — GDPR and Italian Legislative Decree 196/2003 as amended), Italian labour law, and applicable anti-corruption laws (in particular Italian Law 190/2012 and Article 2635 of the Italian Civil Code).
Your responsibilities
Who must comply with the Code
This Code applies to all Eurisko personnel: directors, managers, employees and collaborators of any kind. In addition, external consultants, interns, trainees and any third party acting in the name or on behalf of Eurisko are required to abide by the principles of the Code in carrying out their activities.
Acting ethically and respecting the law, the Code and company procedures
Each of us is personally responsible for always acting ethically and respecting the law, the Code of Business Ethics, and Eurisko's policies and procedures. Violations damage the relationship of trust with the company and with clients and may result in disciplinary action — including termination of employment or collaboration — as well as possible individual civil and criminal liability.
Eurisko's values are consistent and applicable in any context. We recognise that certain practices, even when well established, may violate our ethics: in such cases, doing the right thing requires courage. Saying no to these practices does not mean a lack of respect for colleagues, clients or suppliers: it means protecting the trust that is at the foundation of our work.
Understanding and complying with client codes of conduct
Working as consultants at our clients' premises and on their systems, it is our responsibility to know and respect the client's code of conduct, in addition to this Code. There may be restrictions — on gifts, hospitality, physical or IT security, system and data access — that are stricter than ours: in such cases, we comply with those of the client. When a client's code of conduct appears to conflict with our Code, we discuss it with the client and with Eurisko management.
Cooperation with internal investigations and asking questions
We fully cooperate with all internal investigations initiated to ascertain possible violations of the Code. For any question about your responsibilities or the contents of this Code, contact your reporting line, the management, or the dedicated address indicated in the internal procedures. No question is trivial: asking first is always better than acting in doubt.
Making the right decisions
Issues do not always have a clear and obvious solution. In difficult situations, use your judgement and involve others to help you make the right decisions.
- Obligations under the law — Could it be illegal?
- Obligations to Eurisko — Could it violate our values, the Code of Business Ethics or our policies?
- Obligations to others — Could it violate an obligation toward a client, a supplier or another partner (contracts, confidentiality agreements, client codes of conduct)?
- Do no harm — Could it harm someone, your personal reputation, or Eurisko's brand, reputation, financial performance or commercial relationships?
If the answer to any of these questions is «yes», don't do it.
How to raise concerns
Speak up if you experience first-hand or witness disrespectful, inappropriate, fraudulent, unethical or illegal conduct, including any retaliation. You can always make a report to your manager, to the management, to the Human Resources point of contact, or to the Supervisory Body established pursuant to Italian Legislative Decree 231/2001. If you do not receive an adequate response from the first source you turned to, you may always turn to another channel, without fear of retaliation.
Eurisko makes a dedicated channel available for reports of unlawful or irregular conduct, in compliance with Italian Legislative Decree 24/2023 (whistleblowing). The channel ensures the confidentiality of the identity of the reporter, the reported person and any other party involved, as well as the content of the report and related documentation.
Eurisko applies a zero-tolerance policy toward retaliation against anyone making a report in good faith or cooperating with an internal investigation. The following are forbidden in particular:
- Disciplinary sanctions, demotions, denial of promotions, unjustified transfers or dismissal.
- Adverse changes to working hours, compensation or assigned duties.
- Mobbing, isolation, intimidation, threats or any other form of pressure, even verbal or indirect.
Retaliatory conduct is itself subject to disciplinary action and, where the conditions are met, to reporting to judicial authorities.
The six fundamental behaviours
Our Code of Business Ethics consists of six fundamental behaviours that apply to every one of us at all times.
01 Conduct matters
Respect, availability and shared ethical values are at the heart of Eurisko's culture. Our interactions are guided by mutual respect. Eurisko does not tolerate disrespectful behaviour, harassment or threats of any kind. It is not always relevant whether disrespectful or harassing conduct is intentional: what matters is how it is perceived by the person involved.
- Repeatedly raising your voice, or using vulgar or degrading language toward a person or their work.
- Personal insults, humiliation or intimidation — including via email, Microsoft Teams, WhatsApp or other messaging tools.
- Bullying, mobbing, abusive behaviour or uncontrolled fits of anger.
- Spreading gossip with the intent to harm someone; deliberate exclusion from team activities; unwanted physical contact.
- Sexual harassment, in any form — verbal, written, physical or via digital content.
Meritocracy and non-discrimination. All decisions relating to personnel — recruitment, hiring, compensation, training, assignment of duties, promotions, evaluations — must be based exclusively on individual contribution, demonstrated skills and business needs. Eurisko does not discriminate against any person on the basis of age, sex, pregnancy or maternity, marital or family status, sexual orientation, gender identity or expression, race, ethnicity, national origin, religion, creed, political opinions, trade union membership, disability or any other characteristic protected by law.
Resolving conflicts of interest. A conflict of interest is a situation in which a person — or their family member, relative or friend — has personal interests that may influence their ability to act in Eurisko's best interest. The most important thing in such cases is to promptly report the situation to management, obtain the necessary approvals and comply with any restrictions indicated.
02 Respect the law
We respect all applicable laws and regulations — local, national, European and international. Eurisko's people are responsible for understanding the regulations applicable to their area of activity and for turning to management in case of doubt.
Organisation Model and Italian Legislative Decree 231/2001. Eurisko adopts an Organisation, Management and Control Model pursuant to Italian Legislative Decree 231/2001 in order to prevent the commission of the predicate offences provided for by the regulations. All those operating in the name or on behalf of Eurisko are required to know the Model, to respect its protocols, and to promptly report to the Supervisory Body any violations or suspected violations.
Anti-corruption. Eurisko's position is simple: corruption is wrong, it is against the law, and we neither pay nor accept bribes — in any form and for any reason. We comply with applicable anti-corruption laws — in particular Italian Law 190/2012, Article 2635 of the Italian Civil Code (private-to-private corruption) and the relevant provisions of Legislative Decree 231/2001 — without exception.
Before providing or accepting a gift, a meal, a form of entertainment or a trip, verify that it is:
- Offered for a proper purpose and not aimed at obtaining an improper advantage or influencing the recipient.
- Permitted by applicable law.
- Permitted by Eurisko's internal policies and procedures.
- Permitted by the recipient's policies and the contractual agreements with their employer.
- Of reasonable value and proportionate to the circumstances and the professional relationship.
If even one of these criteria is not met, the gift is inappropriate.
Privacy and personal data protection. We comply with EU Regulation 2016/679 (GDPR), Italian Legislative Decree 196/2003 and further applicable provisions when we collect, store, use or transfer personal data — be they of colleagues, candidates, clients, suppliers or third parties. We adopt appropriate technical and organisational measures and immediately report to management any suspected personal data breach.
Fair competition. We are fierce competitors, but honest ones. Eurisko pursues business exclusively on the basis of its own merits. We do not collude with competitors on prices, offer conditions or market and customer sharing, and we do not improperly use confidential data of competitors, clients, suppliers or former employers.
03 Create value for our clients
Regardless of our role, we are all in the service of Eurisko's clients, focusing on the client's true interests while acting as ambassadors of the company. The principle "We are customer centric" is not a slogan: it is the operating rule that guides every technical, methodological and behavioural choice we make.
Innovation, value and results. We bring concrete innovation to our clients, adapting quickly to change and proposing solutions built on the client's real processes. Acting in the client's best interest does not mean saying yes to every request: it means having the courage to indicate alternative solutions or to challenge an approach that does not generate value.
Achieving excellence. We commit only to what we can deliver and we respect the contractual commitments we make. Before making a commitment, we honestly assess the scope of our activities, the skills required, the timelines and the risks of the project. We accurately document activities, deliverables and timelines, and we promptly report any deviations.
Confidentiality and protection of client information. Working as consultants, we access data that represents our clients' strategic assets — financial data, master data, bills of materials, price lists, system configurations, custom ABAP code, business processes, transformation plans. We treat all this information as strictly confidential, even in the absence of an explicit confidentiality marking.
- We use client information exclusively for the purposes of the current project, never for other projects, other clients or personal purposes.
- We do not share it with anyone who does not have an actual need to know for the project.
- We do not discuss project matters in public places where others may listen.
- We do not duplicate data, configurations or developments on unauthorised devices or media.
- When a project ends we return or destroy client materials according to agreed procedures, and we respect non-disclosure agreements (NDAs) even beyond the contract.
04 Protect people, information and the company
We work together to build a solid and stable company, protecting the Eurisko brand, respecting our commitments to data and intellectual property protection, and taking care of our people.
Information security. We protect Eurisko's, clients' and other parties' confidential data from unauthorised use or disclosure. If we are not sure whether information is confidential, we treat it as if it were.
- We use company or client-provided computers — never unauthorised personal devices to handle Eurisko or client data.
- We do not install software or modify configurations that could compromise device security.
- We do not use cloud services, file-sharing or third-party web tools (Dropbox, personal Google Drive, WeTransfer, ChatGPT, etc.) for Eurisko or client data unless explicitly approved for that use.
- We protect access with strong passwords and multi-factor authentication; we do not share credentials with anyone.
- We lock devices when we step away and immediately report any loss, theft or unauthorised access.
Intellectual property. Custom ABAP code, SAP configurations, data models, process mappings, functional documentation and delivery methodologies are valuable assets. We respect the intellectual property rights of clients, suppliers and former employers: we do not use or bring into Eurisko documents, code or confidential materials from a previous employer, and we do not download copyright-protected materials without the proper licence.
Social media and brand. When we publish on LinkedIn or other channels we represent, even indirectly, Eurisko. We do not identify a company as a client without explicit authorisation, we do not post screenshots of systems, code or project documentation, and we clarify that professional opinions are personal unless authorised to speak on behalf of the company. All official communications to media and institutions are coordinated by management.
Workplace safety. Personal safety is a priority. We respect all applicable safety and emergency procedures — including those provided by Italian Legislative Decree 81/2008 — both at our own premises and at client premises.
05 Conduct business activities responsibly
We are proactive and act as entrepreneurs and owners of the work we do. We spend Eurisko's resources as if they were our own — with care, responsibility and transparency.
Responsible use of data and AI. We use data and new technologies — including artificial intelligence — responsibly. When we use generative AI tools we take responsibility for verifying the output before using it. We do not enter confidential Eurisko or client data into such tools unless the tool has been explicitly approved and there are contractual guarantees on data protection. We declare, when required, the use of AI tools in our deliverables.
Financial reporting and documentation. We prepare and provide complete, accurate and timely financial and operational information, in compliance with the Italian Civil Code and tax regulations. When an investigation, dispute or audit is in progress or anticipated, we do not destroy, modify or hide relevant documents.
- We record working hours in the company system within the deadlines, accurately and truthfully — without opportunistic rounding, shifting between projects or compensation across periods.
- We do not ask or suggest to anyone to report hours inaccurately or untruthfully.
- We submit expense reports with complete supporting documentation, in compliance with policies on caps and reimbursable expenses.
- We do not include in expense reports costs not incurred or not attributable to work purposes.
Business travel and procurement. We organise travel efficiently, balancing project needs, costs, timelines and environmental impact, and evaluating virtual alternatives when equally effective. We purchase goods and services based on their value and select suppliers and collaborators who operate according to principles consistent with our Code and applicable regulations.
06 Be a good citizen
We support and respect human rights, promote environmental responsibility and encourage our people's engagement in the communities in which they live and work.
Human rights. We adhere to the principles of the International Bill of Human Rights and of the ILO Declaration on Fundamental Principles and Rights at Work, focusing on diversity and equal opportunities, working conditions and labour relations, health and safety (Italian Legislative Decree 81/2008), supply chain and privacy.
Environmental responsibility. We reduce the environmental impact of our activities through concrete choices: efficient use of energy and materials at our office, reduction of physical travel when virtual meetings are equally effective, and responsible management of electronic devices and technological waste.
Community impact. We support Eurisko people who dedicate their time, skills or resources to volunteer initiatives, training, mentorship or support for the communities in which we live. We believe that sharing technical and professional skills — especially toward young people, students and organisations operating in contexts of fragility — is one of the most concrete ways in which a consulting firm can contribute to its territory.
Thank you
For your daily commitment to doing the right thing.
Eurisko S.r.l.
Via Burolo, 1 — 10010 Cascinette d'Ivrea (TO), Italy
VAT 08407400012 · Email: info@euriskosrl.it
PEC: eurisko.srl@pec.it