Code of Ethics and Conduct

Why a Code of Ethics

Since 2009, Panta Ray has helped organisations of every size and kind to prevent, manage and overcome adverse events. To do so, our clients entrust us with their most sensitive assets: confidential information, continuity plans, crisis scenarios.

Resilience is built on trust. This Code sets out the values and rules of conduct through which we earn our clients’ confidence every day. They apply to us and to anyone who works with us or on our behalf.

1. Who it applies to

The Code applies to directors, employees, consultants and collaborators in any capacity, and to suppliers, business partners, agents and anyone acting in the name or on behalf of PANTA RAY S.r.l. (the “Company”). Compliance with it is a condition for establishing and continuing any relationship with the Company.

2. Our values

• Integrity: consistency between what we say and what we do.
• Respect for people: inside and outside the organisation.
• Independence: our professional opinion cannot be swayed by interference.
• Expertise and methodological rigour: we speak about what we know.
• Confidentiality: what is entrusted to us is handled with care.
• Responsibility: towards our clients and the context in which we operate.

3. Our commitments to clients

3.1 Competence and honest commitments

We take on engagements only if we have adequate expertise and operational capacity. We describe achievable results truthfully and do not make commitments we cannot honour. Fees are transparent and agreed in advance.

3.2 Independence and conflicts of interest

We maintain our independence of judgement even when our professional conclusions are not welcome to the client. We avoid situations in which a personal interest could interfere with the objectivity of decisions or with clients’ interests: any conflict, even a potential one, is disclosed without delay and managed before it has any effect.

When we assist clients who compete with each other, or when we propose third-party platforms that we resell, we make this explicit to the client.

3.3 Confidentiality

Information acquired during engagements, in particular impact analyses, business continuity plans, crisis scenarios, vulnerabilities and security data, is treated as strictly confidential and used solely for the purposes of the engagement. The duty of confidentiality continues after the relationship has ended.

3.4 Personal data and information security

We process personal data in accordance with Regulation (EU) 2016/679 and local and international laws, following the principles of lawfulness, minimisation, purpose limitation and security. We adopt technical and organisational measures in line with the principles of ISO/IEC 27001, internal rules on the use of systems and access management, and procedures for the prompt reporting of security events.

3.5 Responsible use of artificial intelligence

We may use artificial intelligence tools in our work, but we do not enter clients’ confidential information into them unless they offer adequate contractual guarantees. Every output remains the responsibility and under the control of the professional, who validates it in full.

3.6 External communication

Our public communications are accurate and not misleading. References to clients, engagements or results are shared only with the permission of the client concerned. Those who work with us use their personal channels in a way that does not harm the Company or its clients.

4. Our commitments to people

4.1 Respect and equal opportunities

We recognise the central role of people, guarantee equal opportunities and value skills without discrimination. We do not tolerate harassment, bullying, intimidating or offensive behaviour, or abuse of position.

4.2 Working conditions and human rights

We comply with labour and social security legislation and support international human rights principles. We exclude any form of forced, undeclared or child labour, including in our supply chain, in line with the commitments undertaken contractually under the Modern Slavery Act 2015.

4.3 Health and safety

We work fully remotely and adopt the measures required by law to protect the health and safety of our collaborators, paying attention to remote working and to visits to client premises, whose access and safety rules we respect.

5. Our commitments to partners and suppliers

We select suppliers and partners according to objective criteria of competence, reliability and fairness. We ask them to respect ethical principles equivalent to those of this Code and, where provided for by contract, specific security and integrity standards.

6. Our commitments to the market and society

6.1 Legality

We operate in compliance with the laws and regulations of every jurisdiction in which we work. No interest of the Company justifies non-compliant conduct, and an economic advantage is never a mitigating factor.

6.2 Business integrity

We do not tolerate any form of corruption, active or passive, direct or indirect, towards public or private parties. Detailed rules are set out in our Anti-Corruption Policy, which complements this Code.

6.3 Fair competition

We compete on the quality of our service. We do not discredit competitors, we do not acquire others’ confidential information by improper means and we do not take part in agreements that restrict competition.

6.4 Accounting transparency and anti-money laundering

We record every transaction completely, accurately and with supporting documentation. We do not enter into business relationships with parties whose identity or the lawful origin of whose funds cannot be verified, and we use only traceable means of payment.

6.5 Environment

As far as the nature of our business allows, we reduce our environmental impact: we limit unnecessary travel, go paperless and manage electronic equipment responsibly.

7. How to report a breach

Anyone who becomes aware of a breach, even a suspected one, of this Code can report it using the contact details on the Contact page of pantaray.eu, writing “Confidential report” in the subject line. Reports are handled under the Anti-Corruption Policy, which protects the confidentiality of the person reporting and prohibits any retaliation.

8. Breaches

Failure to comply with the Code may lead, depending on its seriousness and the nature of the relationship, to disciplinary measures for employees, termination of the contract for consultants, collaborators, suppliers and partners and, where applicable, legal action.

9. Review

The Code is reviewed at least once a year and updated in response to changes in the law, the organisation or the context in which we operate. The version in force is always available at www.pantaray.eu.

This English version is provided for convenience. In the event of any discrepancy, the Italian version prevails.