Preamble and scope
This Code of Ethics defines the fundamental principles and values guiding ICMED S.r.l.'s operations and is an integral part of the integrated Management System compliant with ISO 9001:2015, ISO/IEC 27001:2024 and UNI/PdR 125:2022.
The Code applies to all personnel, collaborators, consultants, lecturers, tutors and anyone acting on behalf of ICMED. Violation of its provisions constitutes a contractual breach.
Conflict of interest
The Sole Director, personnel and all recipients of this Code are required to avoid any situation that may constitute a conflict of interest, including potential conflicts, between professional activities carried out on behalf of ICMED and personal or third-party interests.
Any situation that may give rise to a conflict of interest must be promptly reported to the Management.
Confidentiality and data protection
ICMED ensures the protection of data and information acquired in the course of its activities. All recipients of the Code are required to respect the confidentiality of company information, client data and stakeholder data, in compliance with EU Regulation 2016/679 (GDPR) and the internal procedures of the Information Security Management System (ISMS).
Confidential information may not be used, communicated or disclosed without specific authorisation.
Relations with Public Administration
In its relations with Public Administration bodies, ICMED operates in full compliance with applicable regulations, with particular reference to Italian Legislative Decree 231/2001.
It is forbidden to offer, promise or pay — directly or indirectly — money, goods or other benefits to public officials or persons in charge of a public service, in order to obtain undue advantages for the company.
Financial transparency
ICMED is committed to ensuring the highest transparency in accounting and administrative management. Every operation and transaction must be correctly recorded, authorised, verifiable and legitimate.
Financial statements and corporate communications faithfully reflect the company's assets, economic and financial position.
Protection of individuals and equal opportunities
ICMED protects the dignity and fundamental rights of every person and promotes an inclusive working environment, free from any form of discrimination, harassment and abuse, with a zero-tolerance principle.
The company guarantees equal opportunities for access to employment, training, professional growth and remuneration, regardless of gender, age, sexual orientation, ethnic origin, religion or any other personal condition.
ICMED recognises diversity as a resource for innovation and is committed to:
Ensuring pay equity between genders for equal roles, skills and experiencePromoting work-life balance through flexible working hours, smart working and shared parental leavePromoting inclusive communication and equal gender representation in training and scientific eventsProviding an accessible and, if requested, anonymous reporting channel for non-compliant behaviourEnsuring protection from retaliation for those who report in good faith
Sanctions
Violations of this Code of Ethics and company information security policies are subject to disciplinary proceedings proportionate to the severity of the infringement:
Verbal warning for minor or first-level violationsFormal written warning in case of recurrence or intermediate-severity violationsTemporary suspension from duties for serious violationsTermination of the contractual relationship for very serious or repeated violations
Sanctions are applied in compliance with applicable legislation and contracts.
This Code of Ethics is communicated to all personnel, collaborators, lecturers and stakeholders. It is reviewed at least annually by the Management as part of the Management Review.
Sole Director
Vincenzo Iaconianni