Code of Conduct

Code of Conduct

  1. INTRODUCTION

QLT is a law and tax firm established as a professional association offering legal and tax advice and assistance to Italian and foreign companies in all areas of law, with its own offices in Rome and Milan.

With the awareness of the importance of integrating professional success with Environmental, Social and Governance (ESG) principles, QLT LAW & TAX – Studio Legale e Tributario Associato (hereinafter, the “Firm”) – adopts and promotes high standards of conduct towards all its professionals, employees and collaborators.

ESG aspects are systematically integrated into all of the Firm’s operations, making sustainability an integral part of daily processes and practices.

The Firm is guided by the principles of the United Nations Global Compact, which promotes the adoption of international standards on human rights, working conditions, environmental protection and anti-corruption.

Therefore, the Firm believes it is essential that each member of the organization recognizes the value of the trust placed in its business and is responsible for it, thus contributing to solid, transparent and lasting growth. Ethical and responsible behavior is the basis for building and maintaining relationships of esteem and trust with colleagues, clients, counterparties and the community at large.

This Code of Conduct is also consistent with the principles of professional ethics set forth in the Forensic Code of Ethics and the Code of Ethics of Certified Public Accountants; it forms an integral part of the procedures and practices adopted by the Firm, which are considered fundamental in the performance of its professional activities, as well as the rules of conduct that all those acting on behalf of the Firm are required to comply with.

  1. SCOPE AND ADDRESSEES

  1. This Code of Conduct applies to:

  1. Partners, associates and trainees (“Professionals”);

  2. employees (“Employees”);

  3. third parties working with the Firm in any capacity (“Third Parties”),

(Professionals, Employees and Third Parties collectively the “Addressees”)

Compliance with the Code is binding on all Addressees.

  1. The Code of Conduct is distributed to all Addressees and posted on the Firm’s website.

  2. Addressees must:

  • be familiar with the Code of Conduct and comply with its provisions;

  • refrain from conduct contrary to its principles;

  • seek clarification in case of doubts of interpretation;

  • promote conduct and procedures that are in line with the best practices developed nationally and internationally in the ESG field.

  1. ENVIRONMENTAL STANDARDS

The Firm is committed to minimizing its environmental impact through:

  • Responsible use of resources: reduction of energy, water and paper consumption (promotion of digitization).

Great attention is paid, in particular, to the proper use of heating and air conditioning systems. The same are turned off during the absences of Professionals/Employees, at night and on weekends. In meeting rooms, these systems are turned on only a few minutes before the start of a meeting. Lighting in the passage areas is turned on based on people’s access and automatically turned off if there is no movement, after a predetermined time frame has elapsed. The use of stairs and not elevators is recommended.

  • Sustainable waste management (these are small quantities and non-hazardous): separate collection, proper disposal of printer toner and electronic materials.

In addition, since its incorporation, the Firm has adopted a plastic free policy for all its offices in order to limit the use of plastic as much as possible. Each Professional and Employee has a water bottle and can make use of the still and sparkling water dispensers located in the various areas of the Firm; it is forbidden for Professionals and Employees to bring into the offices and make use of “disposable” plastic plates, glasses and crockery. Water and other beverages are offered to clients through glass bottles and glasses, ceramic cups or highly recyclable material.

  • Sustainable mobility: encouraging low-impact transportation practices (public transportation, car sharing, cycling, smart working). In particular, the Firm is equipped with a computer and communication system that allows Professionals and Employees to be able to access any resources and materials remotely, thus allowing them to limit travel, trips and in-person meetings where not necessary.

  • Sustainable suppliers: preference for suppliers and partners who adopt responsible environmental practices.

  1. HUMAN RIGHTS AND SOCIAL RESPONSIBILITY

4.1. The Firm acts in full compliance with national regulations on human rights, labor protection, and international conventions. It is guided by the principles contained in the Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights, and the core standards of the International Labor Organization (ILO), and is committed to promoting fair and decent conditions in every sphere of its activity.

4.2. The Firm opposes all forms of discrimination against Addressees and candidates, regardless of race, gender, age, religion, political opinion, ethnic or social origin, disability, sexual orientation, nationality or union membership. These principles apply to all stages of the employment relationship, from recruitment to training, from promotion to compensation.

4.3. The Firm ensures safe, fair and dignified work environments, in compliance with regulations on hours, pay and privacy.

4.4. The Firm ensures timely and correct payment of wages in line with legal requirements, including minimum wage, overtime and mandatory benefits.

4.5. The Firm implements all necessary measures to ensure health, safety and welfare in the workplace. Appropriate systems are in place to identify, prevent and manage work-related risks, with the aim of protecting the physical and mental integrity of the Addressees and minimizing occupational injuries and illnesses. Great attention is also paid to mental and physical health and the promotion of work-life balance.

4.6. The Firm promotes the performance by Professionals of pro bono activities with special focus on school education, environmental protection, and assistance to innovative start-ups.

  1. INTEGRITY AND COMPLIANCE

5.1. The Firm bases its business relations on integrity and fairness. It is constantly engaged in verifying compliance with all applicable laws, sectoral regulations and relevant internal provisions in order to prevent economic crimes and unlawful conduct.

5.2. The Firm ensures strict protection of confidential information, preventing its unauthorized dissemination and ensuring its use only for the Firm’s purposes agreed upon in advance.

5.3. The Firm is committed to the protection of personal and confidential data of Addressees and clients, storing them only when strictly necessary or required by law, in accordance with the General Data Protection Regulation (GDPR).

5.4. Any potential conflict of interest is promptly reported and handled in a transparent manner. The Firm’s decisions are based on objective criteria and are never influenced by personal interests.

5.5. Offering or receiving benefits to obtain undue business favors is prohibited. The Firm strictly prohibits any form of corruption, including donations or contributions to public officials or similar figures.

  1. IMPLEMENTATION OF THE CODE OF CONDUCT

6.1. The firm ensures that this Code of Conduct is accessible to all Addressees by personally sending it to the partners of the firm, ensuring their adherence, and posting it on the official website. Where there are more restrictive regulations, these take precedence over the general principles described herein.

6.2. All Partners of the Firm are committed to setting an example in the implementation of the principles underlying the Code of Conduct, as well as to constantly monitor the implementation of the principles of the Code of Conduct, including with a view to improving them over time. The Firm shall supervise the effective compliance with the Code of Conduct, censuring conduct that deviates from the principles and deviating behavioral norms.

6.3. All Addressees are encouraged to report violations of the Code of Conduct, especially those related to unlawful practices. Reports may be made through the following channels:

– internally: by contacting the relevant Partner;

– anonymously: by email to info@qltlex.com.

The Firm guarantees the confidentiality of whistleblowers and the absence of retaliation.

This Code of Conduct was approved and put into execution on May 5, 2025