INTRODUCTION

I. The Legislative Decree n. 231/2001 and the Ethical Code. 
Within the national and regional healthcare framework, the IRCSS G.B. Bietti Foundation for the Study and Research in Ophthalmology ONLUS, (hereinafter also called “Foundation”) is recognized as a reference center for the study and research in ophthalmology and plays an extremely important role in this context. Being a Research and Care Institute of national importance and a non-profit organization with social utility, requires a significant commitment to ensure that the legitimate interests of all stakeholders towards the Foundation are respected: patients, financiers (both domestic and international), employees, collaborators, healthcare professionals, suppliers. As a result, it is necessary for those who work in the Foundation or for the Foundation itself to respect the ethical and behavioral principles of the Foundation, and to ensure that they are respected within the scope of their functions and responsibilities. On 8 June 2001, the Italian legislator issued the Legislative Decree. 231 (hereinafter “Decree”) containing “Rules governing the administrative liability of legal persons, companies and associations, including those without legal personality” (hereinafter “Entities”). With this Decree the principle of liability of Entities for offences committed, in the interest or to the advantage of the Entities themselves, by employees and/or other persons indicated in the art. 5 of the Decree (namely directors, statutory auditors, managers, managers, representatives of the Entity, as well as persons subject to their management or supervision) was introduced, unless, among other conditions, the Entity has adopted and effectively implemented a suitable model of organization, management and control (hereinafter also referred to as the “Model”). In order to adopt a Model in compliance with the regulatory provisions, it is necessary to draw up specific organizational protocols to guarantee an efficient control system for the activities of the entity and its employees.Within these protocols, the adoption of an Ethical Code indicating the general principles of reference to which the entity intends to comply is important. Within these protocols, the adoption of an Ethical Code indicating the general principles of reference to which the entity intends to comply is important.

For this reason, this Ethical Code has been drawn up, whose knowledge and compliance become decisive factors for the proper functioning and recognition of the G. B. Bietti Foundation. This Ethical Code (hereinafter “Code”) is an integral part of the Model adopted, containing, among other things, the general principles and rules of conduct to which the Foundation recognizes a positive ethical value and to which all addressees of the Code must conform. By resolution of the Board of Directors, the Ethical Code may be amended and supplemented, also on the basis of suggestions and indications from the Supervisory Body.

II. Addressees of the Ethical Code 
Given the aim of ethically directing the Foundation's activities, this Code is binding for the President, the members of the Board of Directors and the Board of Auditors, the General Director, the Scientific Director, the Administrative Director and the Medical Director, for all employees of the Foundation, including executives (hereinafter “Personnel”), without any exception, as well as for all those who, even if outside the Foundation, operate, directly or indirectly, for the same. Collaborators for any reason whatsoever, consultants, suppliers, business partners, (hereinafter “Third Party Recipients”). All the subjects indicated in the paragraph will be collectively referred to as “Recipients”. All the Recipients indicated above are therefore required to observe and, to the extent of their own competence, to ensure compliance with the principles contained in the Ethical Code. Under no circumstances may the claim to act in the interest of the Foundation justify conduct contrary to that set out in this document. The Code also applies to activities carried out by the Foundation abroad, while taking into account the differences existing in terms of legislation, social, economic and cultural aspects.

III. Dissemination and training on the Ethical Code

The Foundation undertakes to ensure a timely internal and external dissemination of the Ethical Code by means of

  • distribution to all members of the Foundation's governing bodies and to all employees;
  • affixing in a place accessible to all;
  • making available to Recipients and any other interlocutors on the Foundation's website and on the local network (intranet).

The Supervisory Body appointed under the Decree prepares and carries out training initiatives on the principles of this Code, planned also in consideration of the need to differentiate activities according to the role and responsibility of the personnel concerned, or rather, through the provision of more intensive training and a higher level of in-depth study for those who qualify as "top management" in the same way as the Decree, as well as for those who operate in areas that can be qualified as "at-risk" within the meaning of the Model.

In contracts with Recipients Third Parties, the introduction of clauses and/or the signing of declarations is also envisaged, both to formalize the commitment to comply with the Model and this Code, and to regulate penalties of a contractual nature, in the event of violation of this commitment.

IV. Structure of the Ethical Code 
This Ethical Code consists of three sections: i) in the first one, the general ethical principles that identify the reference values in the Company's activities are indicated; II) in the second one, the rules of conduct dictated in relation to the subjects, including the Recipients Third Parties, required to comply with this Code are indicated; III) in the third one, the implementation mechanisms are regulated, which outline the control system for the correct application of the Code of Ethics and for its continuous improvement.