---

Introduction

SCA intends to perform their activities with the maximum transparency, ethically, with moral integrity and fairness. The professionals and associates of the firm must commit to manifest absolute moral righteousness and to share the firm’s values in the action undertaken under the firm’s name.

The ethics code represents an instrument adopted autonomously and susceptible to changes following the will of the firm. This is done in order to express and apply the principles of professional deontology recognised by the firm as its own.

Therefore, this instrument identifies the collective of values that constitutes the social ethic, guiding principles and fundamentals directives in the firm. These are the guidelines that every part of the firm must follow in order to comply with the standards set out by the firm.

The goals pursued by the ethics code are not just legal and economic, they are dictated by a precise social and moral commitment adopted by the firm as its distinctive trait.

Recipients and Stakeholders

The ethics code applies to SCA and, consequentially, the principles and disposition in the code are mandatory for the firm’s partners, employees, professional, practitioners and more generally to anybody performing an activity under or for the firm’s name.

The partners, the professionals, the practitioners and the employees are hereby defined as “Recipients”. Whereas “Stakeholders” is anybody who has helped generate worth for SCA in the past or in the future.

Compliance Manager

SCA, acknowledging the ethics code as an important collection of its values and a centre point of the firm, has instituted a figure il Compliance Manager, to which the partners gave the responsibility of divulging and implementing the ethics code.

TheCompliance Manager is the figure assigned to receive, analyse and verify the violation allegations of the ethics code, assuring the confidentiality for the reporter.

Applications of the Ethical Code

In the application of this code SCA guarantees:

• An appropriate disclosure, making it available to anybody which is in a professional contact with the firm;
• Regular verifications regarding the observance of the ethics code;
• An appropriate punitive system for violations of the ethics code;
• A regular revision and update of the code with the intent of assuring a code always in line with the evolution of the civil society sensibility, the environmental conditions and the regulations in force;

SCA, wanting to focus the attention on the importance that this code holds, it considers the code the standard for the discipline to carry in every work encounter.

The ethics code is given to any third party engaging in any kind of long-term work relation with the firm.

The observance and sharing of the principles contained in the ethics code by third parties not obligated to follow it is one of the criteria adopted by the frim to chose which entities to work with.