Our Code of Ethics

Article 1 – Scope of application

The Code of Ethics identifies the practice’s guiding values and defines the ethical and social profile that must guide the activities of everyone involved in the practice, both in relation to clients and third parties, and within the practice and in dealings with everyone else who works in the practice. Everyone receiving a copy of the provisions contained in the code (the “Recipients”) are all founding partners, associate partners, and the practice’s employees and contract workers.

Article 2 – Responsibility

The Code of Ethics is also based on non-legislative rules and is aimed at each person’s moral and professional principles. Everybody working at the practice has the moral duty to respect, apply and circulate the values expressed by this Code of Ethics, with regard to the roles attributed to them.

Article 3 – The practice’s guiding values

The practice’s guiding values, which must characterise the daily activities of everybody connected with the practice, are as follows:

  • client satisfaction: this is the provision of products and services which best meet the needs, status, culture and expectations of the practice’s counterparties;
  • personalisation of services: this is the personal involvement in the search for the greatest added value to attribute to all commercial relationships;
  • compliance with internal and external behavioural provisions: this is the continuous search for operating methods in line with the practice’s organisation and with primary and secondary legislative provisions;
  • correct behaviour: this refers to the highest standards of behaviour described below in the Code of Ethics, with clients and third parties and within the practice.
  • proper remuneration for the risk assumed by the practice and each member of it: this is the continuous search for fair and appropriate income in line with the complexity and the overall risk attached to the activities carried out, and the quality of professional service offered;
  • priority for investment in support of existing activities and continuous personal development: from a cultural and professional perspective, this is aimed at continually improving the quality provided by the practice.

The guiding values have equal value and must be seen by clients and third parties as factors that distinguish this practice’s operations from those of competing professionals and practices.

Article 4 – Duty of diligence

Recipients of this Code of Ethics act and work with exacting and scrupulous care, in accordance with the rules and with the roles attributed to them, guiding their conduct towards achieving the practice’s objectives and strategy. Specifically, as part of their duty of diligence, each Recipient is committed to meeting the following expectations:

  • punctuality: each Recipient, for the activities under their responsibility, must meet their working commitments in accordance with the timescales established in advance and/or in the timescales required by legal deadlines or by practice. Recipients will not neglect, even temporarily, work that is apparently less urgent or without a particular deadline, but is actually useful to the practice and/or to its clients.
  • completeness: each Recipient, for the activities under their responsibility, must meet their commitments, presenting completed work in the established timescales, and prepared with thoroughness and attention and checked in advance.
  • knowledge: each Recipient, for the activities under their responsibility, must deal with each piece of work critically and with full knowledge of what they are doing.
  • effectiveness/efficiency: each Recipient, for the activities under their responsibility, must deal with each piece of work with the utmost effectiveness and efficiency, optimising the time used and streamlining their work as much as possible.

Article 5 – Duty of professional development and sharing knowledge

The quality of its staff is an asset of fundamental importance for the life and development of the practice. The recipients of this Code of Ethics are responsible for ensuring that their professional knowledge is constantly up-to-date. Particularly, the practice’s partners, employees and contract workers have the duty to keep up-to-date, as a team and independently, on the latest developments on taxation, company and business matters which affect the practice’s activities. Each Recipient is also required to keep other Recipients informed of new developments which they believe is of interest and/or useful to keep skills updated. The practice is therefore committed to supporting Partners, employees and contract workers by paying the costs for databases, specialist magazines and books, where this is believed to be useful for the purpose. To facilitate the exchange of information and mutual growth of knowledge, the founding partners are committed to organising internal meetings for Recipients, possibly on a weekly basis.

Article 6 – Duty of honesty

Everyone connected with the practice works with honesty and moral integrity and refrains from being involved in situations from which personal use, personal advantage or personal convenience may be derived. Recipients of the Code of Ethics are prohibited from:

  • Accepting, directly or indirectly, gifts or other valuables from entities in any way affected by the practice’s activities.
  • Promising or paying sums of money, goods in kind or valuables of any size or value to third parties to promote or favour the practice’s interest or those of current and/or potential clients, and their connected, associated, parent or subsidiary companies.

Exceptions to the above provisions are made for small commercial gifts and favours of modest value (publicity or celebratory objects, invitations to conventions, meetings, gatherings, etc.).

Article 7 – Duty of transparency

In its dealings with clients, proper attention must be paid to illustrating the financial aspects, their significance, the technical structure, the consequences and any risks, providing the client – wishing to receive it – as much information as possible to enable them to make decisions. Written communications, both regular and occasional, must be clear, complete and fully understandable. Requests for information and clarifications from clients, whether written or oral, must be dealt with skilfully, clearly and promptly. In its dealings with the relevant authorities, with the Courts, with the Agenzia delle Entrate [Italian tax agency], with the Guardia di Finanza [Italian financial police] and with other supervisory bodies, the obligatory information must be provided promptly and in full, seeking to comply with the request in the most complete and significant manner possible.

Article 8 – Duty of confidentiality

Members of the practice are required to keep all events and documents of which they become aware in carrying out their work in strict confidence. This applies to clients and the practice and their dealings with third parties. As well as the areas set out in legislation, the obligation of confidentiality includes the practice’s internal organisation, internal regulations, plans, ideas and events and situations that are no longer current.

Article 9 – Duty of commercial fairness

In carrying out their duties as accountants, Partners, employees and contract workers must avoid guiding clients’ choices to solutions that are not appropriate to the client’s culture, standards of quality, and objective requirements in accordance with the law. The activity must be aimed at satisfying the client, avoiding committing the practice to providing consultancy and services without the reasonable certainty of being able to work with an appropriate standard of quality that meet the client’s expectations and standards.

Article 10 – Duty of availability and proactivity

To optimise the efficiency of the professional service offered to clients, each recipient of this Code must also be readily available to the practice and to other recipients, in terms of time and workload (if necessary, especially around the end of financial year, and outside the usual working hours), each in relation to their position within the practice. Each recipient must also be proactive, each in relation to their duties. By proactive we mean:

  • the capacity to help other recipients with their workload, where required or, at least, where necessary;
  • the capacity to recognise the client’s needs and propose possible solutions, even before the client submits them to the practice;
  • the capacity to reply promptly to other recipients and to clients – the capacity to work independently or in a team, as the need arises.

Article 11 – Behaviour in private life

In all circumstances relating to the practice, even outside working hours and away from the workplace, all members of the practice’s organisation must behave with honour for their profession, with a deep understanding of their social usefulness. During working hours and in the workplace, recipients must behave correctly towards colleagues, in accordance with the spirit of partnership. In their private lives, recipients are absolutely prohibited from abusing their position to gain an improper advantage for themselves or for others.

Article 12 – Duty of impartiality

Any differences which may arise within the practice, owing to personal problems or relating to situations between different offices and departments, must be immediately submitted calmly and objectively to a senior member of staff, who will resolve the dispute by considering the nature of the problem, to improve the performance of work and in the interests of the practice.

Article 13 – Use of company assets

Company assets must only be used to carry out practice activities. Everybody connected with the practice must use company assets and equipment with care and attention, avoiding behaviour which may damage the assets, compromise their function or result in financial cost for the practice.

It is absolutely forbidden to use any type of practice asset for personal use (apart from exceptional cases and having obtained prior consent) and to remove documents of any type (unless authorised in advance by a senior member of staff), and to use them for personal purposes or those of third parties.

Article 14 – Doubts regrading interpretation

If any doubt arises regarding the application of the provisions contained in the Code of Ethics, awaiting the specific circumstances, recipients must refer the matter to the President of the practice to obtain clarification.

Article 15 – Violations of the provisions of the Code of Ethics

A violation of the provisions contained in the Code of Ethics may result in trust being eroded between the person responsible for the violation and other recipients of the code (and, in more serious cases, between the practice and clients).

Therefore, in particularly serious cases, and considering the circumstances, a violation of the rules contained in this “Code of Ethics” may result in the consequences set out in company terms and conditions and by existing contracts, and in criticism (and, in the most serious cases, censure) from the majority of the other partners, including the “founders”.

Article 16 – Modifications and supplementations

Modifications and supplementations to this “Code of Ethics” will only be effective if they are signed by the majority of the practice’s Partners – including the founder partners – in post when the modifications/supplementations are made.

Milan, 11th June 2019
Signed by all members of the practice on 11th June 2019
Text agreed and signed together with Studio Associato Carbone Frascati Colombo

Studio Holzmiller & Partners