UPDATED IN JANUARY 2026
1. Introduction
1.1. Objectives
GRID+ S.r.l. (hereinafter also referred to as the “Company” or “GRID+”), with its
registered office at Via Andrea Ferrara 45, Rome, is an innovative start-up operating in
the field of research, development, production and marketing of innovative products
and services with high technological value.
The Company carries out its activities in fields characterised by high technical
complexity and significant economic and social impact, including, in particular, artificial
intelligence, machine learning, data-driven technologies, cybersecurity, e-health, the
green economy, logistics and sustainable mobility, quantum computing, the protection
of cultural heritage, as well as, to a lesser extent, the development of Big Data platforms,
the Internet of Things, robotics and systems for the sharing economy.
Precisely because of the sectors in which it operates, Grid+ recognises legality, fairness,
transparency, accountability, security, data protection, professional quality and
sustainability as essential and non-negotiable values underpinning its business. The
Company is, in fact, aware that technological innovation, to be truly such, cannot be
separated from respect for the individual, the protection of stakeholders’ interests and
the adoption of ethically oriented business conduct.
This Code of Ethics (hereinafter also referred to as the “Code”) therefore sets out the
principles and rules of conduct to which GRID+ intends to align its organisation and
operations, both in its internal dealings and in its external relations. It represents the
framework of values to which all those working for the Company or in its interests must
adhere.
The pursuit of GRID+’s economic and business objectives cannot, under any
circumstances, justify conduct that contravenes the law, professional integrity, the
confidentiality of information, the protection of personal data, the safety of individuals
or the responsible use of technology.
1.2. Adoption and scope of application
This Code is adopted by GRID+ S.r.l. by resolution of the CEO on 12 January 2026.
The provisions of the Code apply to the CEO, shareholders, employees, collaborators,
consultants, external professionals, business partners, suppliers and, more generally, to
all persons who, in any capacity, act in the name, on behalf of or in the interests of the
Company.
Those to whom the Code applies are required to be familiar with its contents, to observe
its principles and to ensure that their conduct complies with them. GRID+ also promotes
the dissemination of the Code’s principles among third parties with whom it maintains
professional or commercial relationships, reserving the right to require compliance with
them to the extent consistent with the nature of the relationship established.
1.3. Dissemination and Publicity
The Code is brought to the attention of its recipients through appropriate means
designed to ensure that it is effectively understood. The Company promotes its
dissemination both within its own organisation and, where appropriate, to third parties
with whom it has dealings.
Each recipient is required to read it, understand its content and ensure that their
activities comply with the principles set out therein. GRID+ also promotes, to the extent
compatible with its organisational size, information and training initiatives on the most
relevant topics in relation to its activities, such as corporate compliance, data protection,
cybersecurity, fairness in commercial relations and responsible use of innovative
technologies.
1.4. Updates
This Code is subject to periodic review and may be amended or supplemented by
decision of the CEO, in order to ensure that it remains in line with changes to the
company’s structure, its activities, organisational requirements and the relevant
regulatory framework.
2. Rules of conduct
2.1. General Principles
2.1.1. Compliance with the Law
GRID+ recognises compliance with the law as a fundamental and non-negotiable
principle of its business. All persons to whom this Code applies are therefore required,
within the scope of their respective roles and responsibilities, to comply with applicable
legal provisions, as well as the principles of fairness, good faith, transparency, diligence
and professional integrity.
The Company shall not establish or maintain relationships with parties who express an
intention to act in breach of the law or in contravention of the ethical principles underpinning this Code. Anyone who becomes aware of requests, solicitations or
conduct likely to induce unlawful behaviour or conduct that is otherwise inconsistent
with GRID+’s principles is required to report this promptly in accordance with the
internal procedures adopted by the Company.
2.1.2. Fairness, verifiability and traceability
Every decision, operation, activity or transaction carried out in the interests of the
Company must be guided by the principles of fairness, transparency, consistency,
verifiability and traceability. This applies not only to administrative or financial
activities, but also to technical, commercial, organisational and relational activities.
Relevant activities must be adequately documented, to allow, where necessary, the
reconstruction of the decision-making process followed, the reasons underlying the
choices made and the responsibilities involved. GRID+ promotes, in a manner proportionate to its structure, organisational practices designed to ensure the reliability
of information, clarity of roles and control over the use of resources.
2.1.3. Integrity and conflicts of interest
In the course of carrying out their duties, all persons to whom this Code applies are
required to act in the interests of the Company, avoiding situations in which personal
interests or those of third parties might compromise the impartiality of decisions or the
proper performance of the duties entrusted to them.
A conflict of interest is any situation in which the private interest of the person
involved, or of persons connected to them, may compromise the objectivity of judgment
or the diligent fulfilment of the responsibilities undertaken towards GRID+. In the event of even a potential conflict of interest, the person concerned must promptly notify the CEO or any other internal contact person designated by the Company, so that
appropriate management and prevention measures can be taken.
2.1.4. Confidentiality and Protection of Information
GRID+ attaches particular importance to the protection of confidential information, its
information and technological assets, know-how, company data, commercial strategies,
technical solutions developed and, more generally, any information acquired or
processed in the course of its business activities.
All recipients of the Code are required to use the information obtained exclusively for
purposes related to their duties or role and within the limits of the authorisations
received, refraining from any misuse, unauthorised disclosure, alteration, theft or
exploitation for personal purposes or in the interests of third parties.
Particularly rigorous protection must be ensured for software, algorithms, models,
datasets, technical documentation, access credentials, system architectures, commercial
information and any other element constituting part of the Company’s intangible assets.
2.1.5. Protection of personal data
The protection of personal data is a core value for GRID+, particularly given the sectors
in which the Company operates and the technologies it develops or uses. The Company
is therefore committed to processing personal data in accordance with the principles of
lawfulness, fairness, transparency, data minimisation, accuracy, security and
confidentiality, in compliance with applicable legislation.
All those who, for reasons related to their work, have access to personal data are
required to process it exclusively within the limits of their duties, the instructions
received and the permitted purposes, taking all necessary precautions to prevent
unauthorised access, improper disclosure, loss, alteration or excessive use.
Particular attention must be paid to processing operations involving data relating to
sensitive contexts or likely to have a significant impact on the rights and freedoms of
individuals, such as in the case of data relating to health, safety or decision-making
processes supported by advanced technologies.
2.1.6. Responsible use of innovative technologies
In view of its corporate purpose, Grid+ recognises that the development and use of
systems based on artificial intelligence, machine learning, data-driven tools, automation
and other advanced technologies entail specific responsibilities. Technological
innovation must, in fact, be pursued in a manner consistent with the principles of
reliability, security, robustness, proportionate transparency, human oversight where necessary, and the protection of the legitimate rights and interests of those involved.
The Company therefore undertakes to guide the design, development, testing and
marketing of its solutions in accordance with criteria of technical and organisational
responsibility, avoiding improper, unlawful or potentially harmful uses of the
technologies developed or adopted.
All those to whom the Code applies are required to act with particular caution in
contexts where the solutions developed or used by GRID+ may have significant effects on
individuals, organisations, essential services or decision-making processes, especially in
sectors with the highest social and ethical impact.
2.1.7. Combating corruption and improper conduct
GRID+ rejects all forms of corruption, favouritism, collusion or undue pressure, both in its dealings with public bodies and with private entities. No one, acting in the interests of the Company, may offer, promise, request or accept money, goods, benefits or other advantages intended to improperly influence the decisions or conduct of others.
Consequently, any conduct which, even if only in appearance, could compromise the
recipient’s independence of judgement or the integrity of the Company is prohibited.
Any gifts, entertainment expenses, invitations or forms of hospitality are permitted only
if they remain within reasonable limits and of modest value, if they comply with the
law, are consistent with normal commercial courtesy practices and cannot be interpreted
as means of obtaining undue advantages.
2.2. External Relations
2.2.1. Competition and Market Fairness
GRID+ believes in free and fair competition and conducts its business in accordance with
market rules, professional integrity and transparency of information. The Company
rejects any practice aimed at unduly distorting the conditions of competition, spreading
false or misleading information, denigrating competitors or gaining competitive
advantages through improper conduct.
All external communications, whether commercial, institutional or promotional in
nature, must be truthful, clear, verifiable and non-misleading. In particular, the
characteristics of the products and services offered must be presented accurately and in
line with the actual capabilities, performance and limitations of the proposed solutions.
2.2.2. Relations with the Public Administration and public bodies
Relations with the Public Administration, with persons performing public functions,
with the authorities, with supervisory bodies and with any other public body must be
characterised by the utmost integrity, transparency, cooperation and compliance with
the law.
In such relations, it is prohibited to engage in conduct aimed at improperly influencing
decisions, obtaining favourable treatment, establishing undue preferential relationships
or securing undue advantages. Similarly, it is not permitted to provide false, incomplete
or misleading statements or documents, nor to use public funds, subsidies or resources
for purposes other than those for which they may have been granted.
Where the Company engages consultants or other third parties in its dealings with
public authorities, it requires such parties to adhere to the same principles of legality,
fairness and transparency that bind GRID+.
2.2.3. Relations with customers and clients
GRID+ focuses its activities on satisfying customers and clients through services
characterised by expertise, clarity, fairness, reliability and quality. In its dealings with
customers, the Company undertakes to provide comprehensive and understandable
information regarding the characteristics of the products and services offered, the
relevant financial terms, the technical limitations of the proposed solutions, and the key operational, security and regulatory compliance aspects.
The Company rejects any misleading commercial practices, any promises that are
technically unsustainable, and any conduct likely to compromise the customer’s free and
informed decision-making. This requirement is particularly important in relation to
solutions based on artificial intelligence or data analysis, in respect of which GRID+
undertakes to truthfully represent both the potential and the technological limitations,
avoiding attributing to the developed systems capabilities, levels of accuracy or
automation that are not adequately reflected in technical reality.
Particular rigour must be observed in projects involving sensitive sectors, such as e-health, cybersecurity, environmental sustainability, mobility and other areas where the use of technology may have significant effects on individuals, organisations or collective
interests.
2.2.4. Relationships with suppliers, consultants, partners and external collaborators
GRID+ bases its relationships with suppliers, consultants, technology partners,
developers, external collaborators and other contractors on criteria of competence,
reliability, transparency, quality, professional integrity and the sustainability of the relationship.
The selection of parties with whom to establish professional or commercial relationships
must be based on objective, reasonable and verifiable assessments, taking into account,
as appropriate, experience, technical capability, organisational reliability, professional reputation, quality of performance and compatibility with the Company’s values.
In managing such relationships, those subject to the Code must avoid favouritism or
unjustified preferential treatment, adhere to the agreed contractual terms, protect
confidential information and promote, where possible, awareness of and compliance
with the principles set out in this Code. GRID+ reserves the right not to enter into or to
terminate relationships with parties whose conduct is incompatible with the principles
of legality, integrity, confidentiality and professional fairness upon which the Company
bases its operations.
2.2.5. Intellectual Property, Know-how and Digital Resources
GRID+ recognises the strategic value of its own and others’ intellectual property and
intangible assets. Software, code, algorithms, models, datasets, technical documentation,
databases, trademarks, content, projects and organisational processes constitute assets
of particular importance to the company’s operations and must be adequately protected.
All persons to whom the Code applies are therefore required to respect the intellectual
property rights of the Company and third parties, refraining from any unauthorised use,
unauthorised reproduction, misappropriation, disclosure or unlawful exploitation of
such assets. The Company’s IT and digital resources must be used exclusively for lawful
professional purposes consistent with the duties performed, in compliance with the
security measures and any organisational provisions adopted by GRID+.
2.2.6. Environment and Sustainability
Although GRID+ operates primarily in the technology and consultancy sectors, it
recognises the importance of environmental protection and sustainability as core values
underpinning its activities. The Company is committed, within the limits of the nature
and scale of its organisation, to promoting responsible behaviour, encouraging the
mindful use of resources, and adopting technological solutions designed to improve
process efficiency and reduce unnecessary environmental impacts.
This approach is particularly significant in projects developed within the green
economy, renewable energy, sustainable mobility and, more generally, in all sectors where technological innovation can make a tangible contribution to the ecological
transition and the more rational use of resources.
2.3. Relations with partners and staff
2.3.1. A people-centred approach and the development of skills
GRID+ recognises the value of the people who contribute to its activities and regards
human and professional capital as a key factor in the company’s growth and success.
The Company promotes a working environment characterised by mutual respect,
collaboration, responsibility, the development of skills and merit.
Decisions regarding recruitment, induction, collaboration, the allocation of
responsibilities and professional development must be based on objective criteria
relating to competence, reliability, aptitude and alignment with the Company’s
organisational needs.
2.3.2. Dignity, equal opportunities and non-discrimination
The Company protects the dignity and integrity of every individual and does not
tolerate any form of discrimination, harassment, abuse, intimidation or offensive
behaviour. GRID+ promotes working conditions that respect the individual and
encourage the celebration of diversity, which is regarded as a source of human and
professional enrichment for the organisation.
All internal relationships must be characterised by fairness, balance and mutual respect,
so as to ensure a healthy, inclusive working environment consistent with the values set
out in this Code.
2.3.3. Health, safety and well-being in the workplace
GRID+ is committed to ensuring working conditions that respect the health, safety and
dignity of individuals, in compliance with current legislation and the technical and
organisational measures that are reasonably applicable in relation to its structure and
the activities carried out.
All those working for the Company are required to contribute to risk prevention, to use
the tools and resources made available to them correctly, and to report any critical
issues or hazardous situations promptly. Safety must be understood not only in a
physical sense, but also as the protection of organisational integrity, workplace
wellbeing and the digital security of the Company’s systems and processes.
2.3.4. Training and a culture of accountability
GRID+ regards training and continuous professional development as essential tools for
fostering a corporate culture centred on compliance, accountability and quality. The
Company promotes, in line with its size and organisational needs, training initiatives on
the topics most relevant to its activities, with particular regard to technological
innovation, IT security, data protection, fairness in commercial relations and the
responsible use of artificial intelligence systems.
3. Implementation procedures
3.1. Internal implementation and responsibilities
The implementation of this Code is primarily the responsibility of the CEO, who
promotes the practical application of its principles, encourages their dissemination and,
within the limits of his powers, adopts the organisational measures deemed appropriate
to ensure compliance.
It remains understood, in any event, that each recipient is personally responsible for
ensuring that their conduct complies with the principles and rules contained in this
Code.
3.2. Reporting of violations or non-compliant conduct
GRID+ encourages the reporting, in good faith, of acts, conduct, omissions or practices
that appear to contravene the law, the principles of this Code, organisational
instructions issued by the Company, or the duties of fairness, security and professional
integrity.
Reports may concern, amongst other things, breaches of the law, undeclared conflicts of
interest, conduct contrary to the Company’s ethical principles, breaches of
confidentiality, critical issues relating to IT security, improper processing of personal
data, discriminatory conduct or behaviour likely to cause harm to the Company, its
customers or other stakeholders.
Reports must be detailed, based on reasonable grounds and made in good faith. They
should be addressed to the external legal department or submitted via internal channels
designated by the Company, such as, for example, a dedicated email address, a confidential written communication or any other internal channel capable of ensuring
adequate confidentiality.
The Company undertakes to examine reports promptly, impartially and confidentially,
whilst respecting the rights of all persons involved.
3.3. Protection of Whistleblowers and Confidentiality
GRID+ protects those who make reports in good faith from any form of retaliation,
penalisation or prejudicial treatment linked, directly or indirectly, to the report. The
identity of the whistleblower and the content of the report are treated with the utmost
confidentiality, within the limits permitted by law and consistent with the requirements
of establishing the facts.
This is without prejudice to the Company’s right to take appropriate measures against
anyone who makes manifestly unfounded reports, made for ulterior motives, or made
with intent or gross negligence.
3.4. Internal Controls
GRID+ adopts, in a manner proportionate to its size and the nature of its activities,
procedures, operational practices and organisational measures designed to promote
compliance with this Code, prevent irregularities and facilitate the timely identification of any critical issues.
These measures are designed, in particular, to strengthen the integrity of processes, the
traceability of relevant activities, information security and the alignment of conduct
with the values declared by the Company.
3.5. Value of the Code and Consequences of Breaches
Compliance with this Code forms an integral part of the duties of fairness, diligence and
good faith to which all addressees are bound, each in accordance with their relationship
with the Company.
Breach of the principles and rules contained in this Code may constitute, depending on
the seriousness of the offence and the nature of the relationship with GRID+, a breach of
contractual obligations, a disciplinary offence within the limits provided for by
applicable legislation, grounds for the adoption of corrective measures or, in the most
serious cases, grounds for termination or withdrawal from the contractual relationship
with employees, consultants, suppliers or other third parties.
The Company reserves the right to assess any breach in accordance with criteria of
proportionality, consistency and respect for the safeguards provided for by law.
4. Final provisions
This Code of Ethics shall enter into force on the date of its approval by the CEO of GRID+
S.r.l.
It serves as the general framework for the Company’s activities and for the conduct of
all those to whom it applies, embodying the values of integrity, responsible innovation,
reliability and respect that GRID+ seeks to uphold and consolidate in its operations.
