Ethical Code

In carrying out its own activity, Atlantyca Entertainment S.p.A. (hereinafter, “Atlantyca”) not only complies with the laws and regulations in force, but it is also its intention to abide by high ethical standards in the daily performance of its own work: the aforesaid standards, together with their inspiring principles, are gathered in this ethical code (hereinafter, the “Code”).

The Code is an instrument which integrates the behavioural rules set forth by national legislators. Pursuant to this decision, Atlantyca requests all business decisions and the conduct of its own staff be based on ethical rules, also if not codified by the law. The term “Staff” means all the persons working in Atlantyca: employees, directors and anyone working for or with Atlantyca (hereinafter, also referred to as the “Collaborators”).

Furthermore, any third party receiving assignments from the Company or having long-lasting relations with the latter, such as outside counsels, suppliers, clients and other persons shall be acquainted with the Code. The aforesaid persons, as a whole, together with the Staff and the Collaborators shall also be hereinafter referred to as the “Recipients”.

The Company is composed of four operations divisions: Animation; Consumer Product; Publishing and Foreign Rights.

Everybody working in Atlantyca shall act in compliance with the rules included under this Code. Special attention shall be requested to the heads of the Divisions, as well as to the members of the Supervisory Body, who have the duty to supervise the Code’s implementation and shall take care of its update. The aforesaid persons shall guarantee that the adopted principles are constantly applied and their conduct shall be an example for the employees and for the Collaborators.

All Recipients shall be requested to abide by the provisions and inspiring principles of this Code.

In this respect, please note that Atlantyca’s internal Organisation has a Legal Department which, amongst others, monitors the correct compliance with the entire national laws and regulations on Intellectual Property, Health and Safety at work, and Data Protection.
The updated version of the Code, which may always be consulted on Atlantyca’s Website, is a contractually binding and fundamental obligation for all Recipients.


1. Behavioural principles

In this respect, please note that Atlantyca’s internal Organisation has a Legal Department which, amongst others, monitors the correct compliance with the entire national laws and regulations on Intellectual Property, Health and Safety at work, and Data Protection. The updated version of the Code, which may always be consulted on Atlantyca’s Website, is a contractually binding and fundamental obligation for all Recipients.

Compliance with laws and regulations
Atlantyca deems compliance with the law to be a fundamental instrument to achieve own targets and to ensure added value for the business and, therefore, in no way shall the Company commence or continue any relation whatsoever with whomever has no intention to align himself with this principle.

Integrity of conduct
Atlantyca is inspired by corporate social responsibility principles protecting all Recipients, thus ensuring it shall use its best endeavours to comply with the aforesaid principles in assigning its own intellectual property rights, as well as for the transparency of its own conduct on the market.

Children work protection
Atlantyca condemns children work and prohibits it in its own employment agreements.

Non discrimination
Atlantyca disavows any type of discrimination based on gender, race, language, personal and social conditions, and/or religious and political belief.

Human Resources enhancement
Atlantyca deems that human resources represent its own main capital and, for said reason, it invests in training Staff, ensuring a healthy and safe work environment, such as to facilitate the fulfilment of all entrusted duties and to enhance each person’s professional skills, furthermore ensuring everybody’s involvement and assumption of responsibilities, as regards the specific targets to be achieved and the ways to pursue the latter.

Trattamento e Protezione dei dati 
Atlantyca collects and processes the personal data of clients, collaborators, employees and other persons (natural persons and legal entities), in full compliance with the provisions in force on data processing set for by the Data Protection Code, namely, Italian Legislative Decree No. 196/2003.
All of Atlantyca’s Staff and Collaborators processing data (either sensitive or not) shall always do so in compliance with the aforesaid provisions and with the operational instructions given by Atlantyca itself to said extent, ensuring the punctual and effective reporting to the relevant bodies.The Staff and the Collaborators shall ensure the greatest confidentiality of any news and information constituting the Company’s assets or pertaining to Atlantyca’s business.Furthermore, in no way shall the Recipients use confidential information for purposes other than the performance of their activity.

For this purpose, Atlantyca:

  • Establishes an organisation for processing information, which ensures the correct separation of roles and responsibilities;
  • Classifies the information per level of increasing criticality and takes the necessary countermeasures in each phase of the processing;
  • Ensures all third parties involved in processing information enter into confidentiality agreements.

Loyalty, Honesty and Fairness
The Staff and the Collaborators working for Atlantyca shall be aware of and shall comply with the Organisational Model and with the laws in force with due diligence to the extent of their respective working activity, thus ensuring full transparency of all actions and conducts. In no way may the pursuit of Atlantyca’s interest justify any conduct failing to abide by the aforesaid principles.

In no way shall the Staff and the Collaborators use any information, goods and equipment for personal purposes, made available in performing the assigned duty or mandate, and in no way shall they accept or take any initiative whatsoever detrimental to Atlantyca or entailing any undue advantages for himself, for Atlantyca or for third parties; each person shall reject, and shall not make, any promise of undue offers of money or of other benefits.

Conflict of interest resolution
In performing their working activity, the Staff and the Collaborators shall pursue Atlantyca’s general targets and interests.

The Staff and the Collaborators shall promptly inform their managers or the heads of the Divisions of the situations or activities in which there could be an interest in conflict with that of Atlantyca, on the side of the Staff and/or the Collaborators themselves or of the respective close relatives, and in any other case in which it may be significantly expedient to do so.

2 Behavioural criteria

2.1 Relations with Staff
Human resources enhancement is one of Atlantyca’s main targets.In recruiting, Atlantyca thus takes the necessary measures to avoid any favouritism and facilitation of any type whatsoever, thus enhancing the skills and abilities of candidates for the full correspondence of the profile to be hired.

Staff shall always be hired with the relevant formal employment agreement; in no way shall any form of irregular employment be tolerated.

When entering into the relevant employment agreement, the following detailed information shall be provided:

  • When entering into the relevant employment agreement, the following detailed information shall be provided:
  • Regulatory and pay data;
  • – Prevention and protection measures in force to protect the health rights connected with the working activity.

Training of Staff
This aspect is primary and fundamental for Atlantyca’s business, thus allocating resources, adequate instruments and time to achieve professional targets.

La formazione è assegnata a gruppi o a singole persone, sulla base di specifiche esigenze di sviluppo di competenze e specializzazioni. Il piano di formazione assicura che ogni persona riceva una formazione adeguata sia all’atto dell’assunzione che in ogni ulteriore passaggio professionaleTraining is provided to groups or to single persons, based on specific needs to develop skills and specialisations. The training plan shall ensure that each person receives adequate training both upon hiring and in any further career advancement.

Institutional and professional training is managed by Atlantyca on a permanent basis

Involvement and participation of people
The involvement of Staff in performing the respective work is ensured, also by foreseeing moments to take part in discussions and to exchange information, which are instrumental to achieve Company targets.

People shall be invited to participate on those occasions with collaboration and judgment independence.

The fact of listening to different points of view – compatibly with the Company’s needs – allows the heads to formulate final decisions; in any event, Staff shall always be under the obligation to take part in the implementation of any and all established activities.

Health and safety
Atlantyca hereby undertakes to provide a work environment capable of protecting the health and safety of its own Staff, whereby the aforesaid obligation shall be considered a productive investment together with a growth and added value factor.

Atlantyca hereby undertakes to spread and to consolidate a safety culture, from a prevention standpoint, raising the awareness of risks and promoting responsible conducts by the Staff and by the Collaborators, who shall be granted adequate information and training, thus guaranteeing the full and precise compliance with the internal rules and procedures, and who shall promptly report any failures or breach of the applicable rules.

2.2. Duties of the Staff and of the Collaborators

The Staff and the Collaborators hereby accept and share the principles set forth under this Code and hereby undertake to implement all business policy provisions on safety at work, data protection and fighting against the crimes foreseen under Italian Legislative Decree No. 231/01 applicable to Atlantyca’s business.

Confidentiality of business information
The information and business assets need be protected with the greatest due diligence. Any strategic information, also concerning the clients to be acquired or created by Atlantyca in doing its own business, shall be considered confidential information and appropriate attention shall thus be put thereto.

All Atlantyca’s Staff and Collaborators shall refrain from taking personal advantage of any business opportunity, of which they may become aware in fulfilling their own duties. Any situation which may entail a conflict of interest is expressly prohibited, including, for instance, the following situations:

  • Doing any business as self-employed in competition with Atlantyca, also through relatives;
  • Having financial interests with suppliers, clients or competitors;
  • Accepting money or favours from persons or companies, who/which are or aim at doing business with Atlantyca

Should a conflict of interest arise, even if only seemingly, the person concerned shall report the latter and shall furthermore provide information on the activities carried out outside the workplace, should they be likely to be in conflict of interest with Atlantyca.

Use of Company goods
Everybody shall act with due diligence in order to protect all Company goods, with responsible conducts and in line with the operating procedures set forth to govern their use, precisely documenting the latter.In particular, everybody shall:

  • Use all entrusted goods with the utmost care;
  • Avoid any illegitimate use of Company goods, which may damage or reduce the respective efficiency or which, in any event, is in conflict with Atlantyca’s interest;
  • Strictly implement the Company’s safety policies, in order not to jeopardise the functionality and protection of IT systems;
  • Refrain from surfing Internet Websites with indecorous and offensive contents and, in any event, unrelated to the respective professional activities.

2.3. Relations with the Recipients

Relations with clients
Communications to clients
Atlantyca shall supervise the communications to client Recipients, ensuring the respective correctness and transparency. Therefore, Atlantyca’s communications, together with any and all provided information shall be:

  • Clear, simple and comprehensive, formulated with words which are comprehensible for interlocutors;
  • Such as not to entail illegal or, in any event, unfair practices;
  • As sufficiently detailed and analytical as not to omit relevant elements for client decision purposes.

The Staff’s way of conduct towards clients
The way of conduct of Atlantyca’s Staff and Collaborators towards its clients is marked by availability, respect and politeness, aimed at a collaborative and highly professional relation.

Relations with suppliers
Supplier choice and management

Purchase processes are marked by the pursuit of the greatest competitive advantage for Atlantyca and by the granting of equal opportunities for suppliers, provided that they ensure compliance with the principles inspiring this Code. The quality-price ratio of the good or service, and the warranties of assistance and timeliness are decisive choice criteria in choosing the supplier.

Atlantyca undertakes to prepare all necessary procedures and actions to ensure the maximum efficiency and transparency in the purchase process and in choosing suppliers, in order not to exclude anyone eligible to said extent from competing for the entering into of agreements, adopting objective criteria for choosing the short list.

Atlantyca constantly monitors the relations with suppliers, including those concerning financial and consultancy agreements.

In order to align all procurement activities with the adopted ethical principles, Atlantyca undertakes to comply with all requirements pertaining to social ethics.

Accounting and managerial transparency
Atlantyca guarantees the maximum transparency of its activity management processes, amongst which, also the entirety of accounting information, which shall be drafted in a clear, complete and comprehensive manner, and made available for any checks. Supporting documents shall specify the criteria adopted in valuing any and all financial items.

IThe relationship between Atlantyca’s Shareholders and corporate bodies (Board of Directors) is ensured by the relevant effective and prompt reporting, which shall be as sufficiently comprehensive as to enable Shareholders’ Meetings to take informed decisions.

The due participation of all Shareholders and of the corporate bodies (members of the Board of Directors) in all Shareholders’ Meetings is ensured.

Protection of corporate assets
Atlantyca’s management is aimed at enhancing and reinforcing corporate assets in compliance with the laws in force, with the By-laws and with the Code, thus protecting Atlantyca and its Recipients. The correct application of this Code and of the corresponding managerial rules relevant for the business meets this need, in order to create added value for Atlantyca and to remove any factors depreciating the business and non-managed risks.

2.4. Relations with the Public Authorities
The term Public Authorities means any person, party, interlocutor, qualifiable as public officer or person in charge of a public service, acting on behalf of the Public Authorities, be them central or suburban, or of public supervisory bodies, independent authorities, EU institutions, together with private partners who are concessionaires of a public service.

Inspiring principles
All Atlantyca’s relations with the Public Authorities shall take place based on the relevant legal and administrative obligations, for express needs for declared purposes, to be managed with the maximum conduct transparency and ethicality, in such a way as not to jeopardise both parties’ integrity.

For this purpose, the Staff and the Collaborators shall refrain from any conduct which may damage the Public Authorities’ impartial and autonomous judgment.The business organisation shall comply with the procedures adopted pursuant to the Data Protection Code, therefore, in carrying out transactions and in liaising with the Public Authorities, everybody shall ensure the maximum transparency and traceability of all relevant information.

Special care needs be taken in those transactions related to tender procedures, contracts, authorisations, permits, licences and requests for public (i.e. Government or EU) funding.

Presents, gifts and benefits

In no way shall anyone working for Atlantyca be entitled to lavish money, or to offer financial benefits or other types of benefits to any person from the Public Authorities, in order to obtain mandates or other benefits, either personal or for Atlantyca.

Should anyone at Atlantyca receive express or implied requests for benefits from a member of the Public Authorities, he/she shall promptly inform his/her hierarchical manager or the person to whom he/she is under the obligation to report, in order for the necessary initiatives to be taken.

2.5 Relations with the community and spreading of information
Outside communication

Atlantyca’s communication towards its own Recipients is marked by the compliance with the right for information, thus precisely implementing all Data Protection Code’s procedures and provisions, as applied by Atlantyca; in no way shall it be permitted to spread false or tendentious news or comments.

Any form of pressure or any favouring attitude by the media is hereby prohibited.

In order to ensure the entirety and consistency of information, Atlantyca’s relations with the mass-media shall exclusively fall within the scope of authority of the departments in charge.

3. The Code’s implementation process

3.1 Spreading and communication
Atlantyca undertakes to spread the Code, by using appropriate means of communication and business tools, amongst which, the company’s Internet Website, information meetings and Staff training.

Also based on the Supervisory Body’s guidelines, Atlantyca shall prepare and shall implement a permanent training plan aimed at ensuring the awareness of the ethical principles and rules set forth herein.Training initiatives shall be differentiated, depending on the persons’ roles and responsibilities; a special training programme is foreseen for newly hired employees, which shall explain the contents of the Code to be complied with.

The Supervisory Body and management are available for any explanation and clarification in connection with the Code.

Everybody, in particular management, shall be responsible for including the Code’s contents in all training programmes and to make reference thereto in all Company procedures, policies and guidelines.

3.2 Supervision of the Code’s implementation
The duty to ascertain the Code’s implementation and application shall fall with:

  • The Board of Directors and the executives of Atlantyca
  • – The Supervisory Body: besides monitoring compliance with the Code, this body shall suggest the appropriate updates to the Code, also based on all Staff’s reports.

The Supervisory Body shall have the following duties:

  • Report to the Human Resources Management Department all notices of breach of the Code received, in order for the aforesaid Department to take all necessary measures;
  • Give opinions on the review of the most significant policies and procedures, in order to ensure consistency with the Code;
  • Contribute to the Code’s periodic review: for said purpose, the Supervisory Body shall formulate appropriate proposals to the Boards of Directors, which shall assess them and, if necessary, approve and formalise them;

3.3 Reporting of problems or suspect breaches
Should anyone become aware, or be reasonably convinced of the existence of a breach of this Code, of a certain law or of any business procedure, he/she shall be under the obligation to immediately inform the Supervisory Bode and/or his/her manager to said extent.

Any such notice of breach shall be made by e-mail to the address communicated by Management: Atlantyca shall take all necessary measures to such extent as to protect all reporters from any type of retaliation, whereby the latter shall be understood as any action which may give cause for any types of discrimination or penalisation (for instance, interruption of all relations with partners, suppliers, advisors, etc.; denial of promotion to employees). For the aforesaid purpose, reporter identity confidentiality shall be ensured, without prejudice to the obligations provided for by law.

3.4 Disciplinary measures following any breach
The provisions of this Code shall be an integral part of the contractual obligations undertaken by the Staff, as well as by all Recipients liaising with Atlantyca. Breach of the principles and conducts under the Code shall jeopardise the relation of trust between Atlantyca and the perpetrators of the breach, regardless of whether they are directors, employees, advisors, collaborators, clients or suppliers.

Atlantyca shall fight against any and all breaches as follows:

  • In so far as all employees are concerned, through appropriate disciplinary measures, without prejudice to the criminal impact, if any, of the conducts and of the issue of the relevant criminal proceedings, should the conducts amount to a crime. In particular, all penalties shall comply with the rules and rationale of the applied employment agreement.
    Disciplinary measures applied to the Staff only may vary from warning or admonition, to suspension without pay, downgrading and, in the most serious cases, to dismissal. Before taking any disciplinary measure, the party concerned shall be permitted to justify his/her conduct pursuant to the Workers’ Statute.
  • In so far as the Recipients other than the Staff are concerned, specific procedures to terminate the respective agreement shall be put into operation.
  • As regards top management, the directors or legal representatives, the Supervisory Body shall formalise the relevant notice to be served on the Shareholders’ Meeting, which shall be called without delay by way of the relevant ordinary meeting upon the Supervisory Body’s express request to said extent, for the purposes of all necessary resolutions.

Furthermore, without prejudice to the compensation for those damages, if any, incurred by Atlantyca as a result of the aforesaid persons’ breach of the provisions of this Code.

3.5 Operating procedures and decision-making protocols
In order to prevent any breach of the laws and regulations in force, and of the Code, Atlantyca foresees the adoption of specific procedures by anyone taking part in the operating process, aimed at identifying the persons liable for the processes for deciding, authorising and carrying out all transactions: it shall be necessary for each single activity to be carried out in the respective different phases by different parties, whose skills shall be clearly established and known within the organisation, in such a way as to avoid unlimited or excessive powers from being granted to a specific person.

All Atlantyca’s actions and transactions shall be appropriately recorded, thus making possible to check the process for deciding, authorising and carrying out all transactions.

There shall be appropriate documentary support for each transaction, in order to expedite any and all controls certifying the characteristics of and grounds for the transactions at any time, identifying the person authorising, carrying out, recording and checking the transaction.

4. Miscellaneous

This Code was approved by Atlantyca’s Board of Directors on 29 March 2012.