People Yield Code of Ethics

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1. PERSONAL RESPECT: No form of discrimination and harassment will be tolerated by People Yield (PY); PY guarantees all stakeholders equal dignity and respect for the person by striving to create and maintain a working environment in which all employees and collaborators of the group are protected.

2. EQUITY: People Yield is committed to maintaining a fair conduct with all stakeholders, especially with its employees/collaborators and customers. People Yield recognizes equal opportunities and assumes fair attitudes towards customers, suppliers and competitors.

3. MERITOCRACY AND PROFESSIONAL GROWTH: People Yield is committed to rewarding the merit of its employees through career advancement and also promotes skills and professional growth by paying particular attention to the constant updating of skills, supporting the career prospects and employability of its employees and collaborators.

4. CLIENT’S INTEREST: People Yield, operating in the interest of the client, does not consider only the individual client of the assignment, but the entire client-organization in whose name and on whose behalf the assignment is given. People Yield carries out the assignments entrusted to it by the client with diligence and care, taking into account the trust that the client places in PY and bringing out the client’s real interests. People Yield respects the intellectual property and assets of the client.

5. TRUST AND TRANSPARENCY: People Yield operates in such a way as to justify and safeguard the trust placed in it by constantly pursuing the client’s interests. People Yield carries out its activities in accordance with the principle of transparency and is committed to bringing to light any problems so that each stakeholder is put in a position to make his or her own choices in a responsible and prudent manner.

6. OBJECTIVITY AND IMPARTIALITY: In formulating its choices and solutions, People Yield operates in an objective and impartial manner, pursuing the interest of the client and preventing conflicts of interest. Should such conflicts arise, the advisor will seek, through impartial agreements, to fairly balance the interests of all parties involved.

7. CONFIDENTIALITY AND PRIVACY: People Yield guarantees the confidentiality of all confidential stakeholder information in its possession and operates in compliance with current privacy legislation.

8. FAIR COMPETITION: People Yield competes with its competitors fairly and in the best interest of the client.

9. LEGALITY: People Yield has as a mandatory principle the respect for the laws, regulations and rules in force in all the countries in which it operates. People Yield refuses assignments that imply the violation of laws.

10. SOCIAL RESPONSIBILITY: People Yield operates in the interest of the common good by guiding clients towards sustainable solutions from a financial, social and environmental point of view. The company is committed to ensuring that the consequences, even if not immediate, of its consulting activities are socially responsible.

11. CORPORATE IMAGE: All People Yield employees and collaborators protect the image, reputation and brand of the company, as well as those of the clients with whom they work.



Professionalism, competence, helpfulness, fairness and courtesy are the guiding principles that the Recipients of the Code are required to follow in their relations with customers and, with a view to continuous collaboration and assistance, are aimed at ensuring customer satisfaction and trust.
In order to protect the image and reputation of the People Yield Company, it is essential that relations with customers are marked:
• full transparency and fairness;
• compliance with the law, with particular reference to anti-money laundering and
anti-usury provisions;
• independence from all forms of conditioning, both internal and external,
• through a lucid and truthful analysis of the assignment at hand.
The company only accepts assignments for which it is competent and, in any case, does not offer consulting services if it is convinced that they are detrimental to the company and/or the client’s organization, including the client’s stakeholders.
Before proceeding with the tender, a risk assessment of the project is always carried out; this assessment covers the following aspects:
• Potential problems, both economic and financial and technical and strategic;
• The availability of resources (both in qualitative and quantitative terms);
• The contents of the project in relation to potential technical or contractual issues;
• Possible problems (if any) of a technical-organizational nature related to the
management of the project.
Specifically, every offer made by the consultant that has an economically significant impact on the client is accompanied by a project analysis that takes into consideration the nature, extent and size of the intervention offered, taking into account the direct and indirect effects of the results and the related consequences on all stakeholders.
Evidence of high project risk may lead to discontinuation of bid processing and abandonment of the assignment.
In the relationships with customers and clients, the Company ensures fairness and clarity in business negotiations and in the assumption of contractual obligations, as well as the faithful and diligent fulfillment of the obligations agreed upon. Specifically, the company is committed to providing information that is always complete, transparent and understandable to all, taking care to ensure that the communication is accurate and faithful, to allow recipients to make informed decisions about the activities carried out by the same and the services offered.
During the commercial offer phase with the client, PY undertakes to formalize in a transparent and clear way the main aspects related to the provision of the service, defining
• contents and methodological approaches;
• commitments and responsibilities;
• expected results (precisely quantified where a commitment to results is required);
• timing;
• resources needed in terms of means/people.
In situations where the client is unable to verify the work, the company behaves in a professional manner and does not take advantage of it to gain undue advantage. In the event of unforeseen events that cause the need to supplement the existing contract, the consultant shall promptly inform the client of the specific nature of such events and the reason why they could not be foreseen initially. In such cases, Recipients do not seek to gain unfair advantage through onerous fees or unnecessary activities, but modify the initial project by proposing new contract terms that would likely have been accepted in an initial agreement.
On the basis of the advice offered to him, the client must be enabled to make his own decisions in a free, responsible and informed way; for this reason, PY favors the focus on the actual interests of the client-organization and the actual objectives of the advice.
The Recipients of this code shall not treat their customers and/or potential customers arbitrarily and unequally, differentiating them according to the economic importance and size of the order, but shall offer them a service that respects the agreed standards.
People Yield does not discriminate against clients on the basis of religious, political, ethnic beliefs or sexual preferences, but – while it does not show preclusion towards any client or category of clients – it does not have any relationship, direct or indirect, with people who are known, or only suspected, to belong to criminal organizations or who operate outside the law.
The behavior adopted is based on respect for the confidentiality of the information acquired during the course of the activity, in compliance with the privacy regulations in force.
Specifically, employees may not disclose, through social media, company and/or client information or, in general, information that has not yet been officially made public, nor may they open blogs and/or pages dedicated to the company without prior and explicit consent from the Administrator.
The addressees of this code are absolutely forbidden to use confidential client information for purposes unrelated to the exercise of their consultancy activities and/or outside the limits provided for by the regulations in force.
If the Recipients hold influential positions within company review processes that may have implications on the organization or distribution of resources, they undertake to act according to the principles of equality, impartiality, integrity, professionalism and non- discrimination. Specifically, the Company must not accept, either from the client or from persons belonging to the company with whom it has come into contact in the course of the consultancy, gifts and/or donations that could even only give the appearance of a limitation of its independence and impartiality.
In general, no form of gift is allowed that may be, even only indirectly, interpreted as exceeding the normal manifestations of courtesy allowed in commercial practice, or in any case aimed at obtaining favorable treatment for the Company or from the Company.
It is absolutely forbidden for Recipients to request and/or accept, directly or indirectly, money and/or gifts and/or favorable services, if this may appear as a counterpart for a service due within the scope of the Company’s business activities.
If it is impossible to refuse or return the gift, or if the refusal could have negative consequences on the relationship, the recipient of the gift must inform promptly to his direct superior, i.e. the company contact person, who will assess the action to be taken.
People Yield is committed to implementing all necessary measures to prevent and resolve potential conflicts of interest. Specifically, in the conduct of any activity, circumstances must always be avoided in which consultants find themselves in the situation, even if only potential, in which interests and/or personal or family activities affect the ability to operate in the total interest of the client.



Interpersonal relationships within the Company are based on the principles of respect, loyalty and transparency. Forms of exploitation, isolation, harassment or induction to stress are not tolerated. The company protects the employee against any possible mobbing action.
The evaluation of the personnel to be hired is carried out on the basis of the correspondence of the candidates’ profiles with those expected and with the specific needs of the Company.
People Yield guarantees fair and equal pay and career opportunities for all employees. By means of a fair and shared evaluation process, the profile of each employee is reviewed on a timeframe defined by internal policies, recognizing possible promotions and career advancement on the basis of results achieved and growth potential.
The remuneration policy for employees is based on the recognition of merit for the contribution made in terms of effort and results; the project manager discusses with the employee the evaluations and decisions that affect him/her in a transparent and objective manner.
People Yield does not improperly use forms of internships, with the sole purpose of taking advantage of cheap skilled labor without actually offering professional growth and ensuring that they are paid.
People Yield promotes gender equality and the enhancement of diversity, pursuing, also through the creation of training and professional qualification opportunities and within the limits of employees’ skills, effective equality of opportunity in access to positions of corporate responsibility.
With reference to decisions relating to the selection of personnel and career advancement of collaborators and employees, People Yield does not discriminate on the basis of gender and sexual identity, race and religious and political beliefs. In this regard, it is specified that promotions and career advancements are expressly explained, and possibly recognized, to all those who cooperate in the creation of added value.
Employees are required to conduct themselves in a way that is always respectful of the rights and personalities of their colleagues, collaborators and third parties, regardless of their role in the company and the operating circumstances in which they find themselves. The respect for and centrality of human resources is a mandatory value for the company: employees are required to comply with this value and the principles deriving from it, behaving with their colleagues in such a way as to promote the establishment and maintenance of a serene, collaborative and healthy environment.
All business decisions must be made in the exclusive interest of the Company. During the performance of their duties, Addressees must avoid situations of conflict of interest deriving from their own personal or family activities (economic or otherwise); in particular, anything that may interfere with their ability to impartially make decisions in the best interests of the Company.
The employees are required to observe a public behavior respectful of PY and the client organization where they work, taking care of them and avoiding to damage them, both inside and outside the company context, as well as during or after working hours. Specifically, the addressees have the duty to protect the corporate image by contributing to its enhancement and refraining from anything that, even indirectly, could affect the reputation of the company itself.
These behaviors must be implemented in the most diverse public and/or private contexts, such as interviews with candidates, meetings or training courses, interactions with customers, publications on social networks, and – in general – in any case in which the company is represented (explicitly or implicitly) externally.
Any action must be based on respect for the person, the image, the good name of the company and its working environment. For this reason, the use and management of social media must ensure the protection of the company and the people who work there.
In addition, employees, when publishing their opinions, are required to specify that such orientations of thought are of a personal nature and do not in any way engage the responsibility of People Yield.
The private use of social networks – which can have an impact on the corporate image and on the working environment – must be based on respect for the company’s principles and awareness that their use implies personal responsibility. Employees are therefore required to avoid unethical attitudes and behavior that may in any way damage or distort the corporate image.
The Recipients will use with responsibility, order and respect the offices – both of the Company and of the clients – and the company equipment, providing for the custody of the company assets entrusted to them (such as personal computers, mobile phones and company cars), it being understood that PY may ask the Recipients to pay compensation for any damages caused by negligence or carelessness.
Each employee and collaborator is required to work diligently to protect the company’s assets through responsible behaviour and in line with the operating procedures established to regulate their use.
In particular, with regard to the use of computer systems, everyone is responsible for the security of the systems used and is subject to the regulations in force and the conditions laid down in the licence agreements.
The personal use of company equipment (PC, mobile phone, car) is allowed as long as it does not harm the efficiency and functionality necessary for carrying out work activities. In any case, the use of the company e-mail must not be detrimental to the image and reputation of the Company.
Each employee and collaborator is also required to make the necessary commitment to prevent the possibility of crimes being committed through the use of IT tools.
The Recipients are aware of the strategic and economic value, for the Company, of the methodologies, processes and working documents developed by People Yield and therefore undertake not to divulge them externally and, in the event of termination of the employment relationship, to return to the Company any document or copy in their possession.
Recipients must also refrain from taking personal advantage of acts or information of which they become aware during the performance of their duties.
Employees and contractors are not permitted to use, in any form, the Company’s name and trademarks for private purposes. Letterhead may only be used for communications signed by a designated Partner or Manager.
The Recipients of the code are aware and accept that all industrial and intellectual property rights relating to the creations and intellectual achievements and the products and services resulting from the professional assignment, are intended to be in full and total ownership and availability of People Yield.
For the sake of decorum and respect for colleagues and customers, Recipients shall wear formal attire both in the office and during visits or transfers to customers.
People Yield requires its employees to know and observe, as far as it is within their competence, the prescriptions of the Code of Ethics and, compatibly with individual possibilities, to promote the knowledge of the Code among new employees as well as third parties interested in the application of the Code of Ethics, with whom they come into contact for reasons of their office.


People Yield shares the value of fair competition, refraining from conduct in contrast with the Community, national and association provisions protecting free competition.
People Yield, therefore, does not engage in systematic unfair competition aimed at taking away a competitor’s human resources, confidential knowledge or relationships with parts of the clientele with the sole purpose of making it impossible for the competitor to be present in a market segment. We do not practice price reductions, not sustainable on the basis of the costs of factors of production, for the sole purpose of eliminating competitors and acquire a dominant market position, so as to be able to abuse it by earning overprofits or offering poor quality services to the detriment of the customer.
In contacts with competing companies, Recipients shall refrain from disclosing the terms and conditions (including economic conditions) practiced by the Company as well as from discussing issues such as services and products offered, methods used, organization and internal policies.
People Yield, in order to achieve the interests of its stakeholders, always works fairly with all the players it meets during its assignment. In addition, for assignments where People Yield does not have all the operational skills or characteristics to manage the activity, it undertakes to follow the assignment also in joint or associated form with other companies even if they are competitors (e.g. ATI – Temporary Association of Companies). In ATI relationships, the partner companies are not considered competitors with exclusive regard to the subject matter of the ATI.
The processes of selecting and choosing suppliers are based on principles of legality, fairness and transparency.
The consultant shall not take undue advantage of contractual dependency relationships in which partners or suppliers may find themselves due to their insufficient information on the activities of the consultant, especially when they establish long-term relationships with benefits in advance of payments and investments by the supplier.
Every purchase in favor of the Companies of the Group must be conducted with loyalty, integrity, confidentiality, diligence, professionalism and objectivity of judgement.
The Recipients involved in the purchasing process:
• are required to comply with the principles of impartiality, transparency, competition and independence in the exercise of the tasks and functions entrusted to them;
• must remain free from personal obligations to suppliers;
• must report to the Supervisory Body any personal relationships with suppliers;
• must maintain relationships and conduct negotiations with suppliers in a manner
that creates a solid foundation for mutually beneficial and long-term relationships in
the best interests of the Company;
• are absolutely obliged to immediately report to the Supervisory Board any attempt
or case of alteration of normal business relations;
• must not offer goods or services, in particular in the form of gifts, to personnel of
other companies or entities in order to obtain confidential information or direct or
indirect benefits that are significant for themselves or for the Company;
• must not accept goods or services from external or internal parties in exchange for the release of confidential information or the initiation of actions or conduct aimed at favoring such parties, even if there are no direct repercussions for the


People Yield manages its business in a way that is compatible with the environment and society around it.
People Yield is also committed to working for its clients in activities within the scope of projects aimed at energy efficiency interventions, providing analysis, services and measures to improve energy efficiency in clients’ installations or premises.


For the purposes of this Code, Public Administration means, in addition to any public body, also any independent administrative agency, natural person or legal entity acting as a public official or public service appointee or as a member of a body of the European Communities or as an official of the European Communities or as an official of a foreign State.
It is not permitted, either directly, indirectly, or through a third party, to offer or promise money, gifts or compensation, in any form whatsoever, or to exert undue pressure, or promise any object, service, performance or favor to managers, officials or employees of the Public Administration or to persons in charge of a public service, or to their relatives or cohabitants, for the purpose of inducing them to perform an act of office or contrary to their official duties, or to their relatives or cohabitants for the purpose of inducing them to perform an official act or an act contrary to the official duties of the Public Administration (this should also be considered as the purpose of favoring or damaging a party in a civil, criminal or administrative process, thus directly or indirectly benefiting the Company).
Anyone who receives explicit or implicit requests for benefits of any kind from subjects of the Public Administration, as defined above, shall immediately:
• suspend all dealings with them;
• inform the Supervisory Body in writing. The requirements indicated in the previous
paragraphs must not be circumvented by resorting to different forms of aid and contributions which, in the guise of appointments, consultancy, advertising, etc., have similar purposes to those prohibited by this paragraph. In the event that commercial relations are undertaken with the Public Administration, including participation in public tenders, it is necessary to always operate in compliance with the law and correct commercial practice. In particular, the following actions must not be undertaken, either directly or indirectly:
• offer or in any way provide gifts;
• solicit or obtain confidential information that could compromise the integrity or
reputation of either party.
It is not permitted to use or present false declarations or documents or ones certifying things that are not true, or to omit information in order to obtain, to the advantage or in the interest of the Company, contributions, financing or other disbursements, howsoever called, granted by the State, a Public Body or the European Union.
It is forbidden to mislead anyone by means of artifice or deception in order to procure an unfair profit for the Companies of the Group to the detriment of others.
The “unjust profit” may be direct or indirect and may include, in addition to contributions, financing and other disbursements granted by the State, a Public Body and the European Union, also concessions, authorizations, licences or other administrative acts.
It is also forbidden to use contributions, financing or other disbursements, however they may be called, granted to the Company by the State, a Public Body or the European Union for purposes other than those for which they were assigned.
It is forbidden to alter in any way the functioning of a computer or telematic system or to illegally intervene in any way on the data, information and programs contained therein or pertaining to it, in order to obtain an unfair profit to the detriment of others.
The consultant refuses to pay sums of money or exchange any form of benefit with persons active in the decision-making process to obtain the award of public contracts, and in general conforms its business conduct to the current principles on the subject of public, Community and national contracts.


The criteria of conduct in relations with the media are based on principles of transparency,
correctness and timeliness.
Relations with the press are maintained exclusively by the Director (except for specific authorizations).
The Addressees shall observe the utmost confidentiality with regard to information relating to Customers. The only public and freely disclosable information on the Company is that contained in the website The Addressees shall refrain from providing other information, rumors or news that are false or misleading.


Recipients are required to scrupulously comply with the regulations in force in the sectors related to their areas of activity and the provisions issued by the competent public supervisory authorities.
PY and the Recipients act in compliance with the principle of sincere collaboration. The communications, reports and answers to requests sent to the public supervisory authorities must be prepared in compliance with the principles of completeness, integrity, objectivity and transparency.
It is forbidden to present untrue facts, even if subject to assessment, on the economic, financial or equity situation of the company or to conceal, with other fraudulent means, all or part of the facts to be communicated concerning the same situation.
In any case, knowingly obstructing the functions of public supervisory authorities in any way is strictly prohibited.


In the performance of the specific activities, PY and the addressees operate in a lawful and correct manner, collaborating with the Judicial Authority and the bodies delegated by the same if investigations are carried out against them. In no case PY or the Recipients behave in a way that may interfere or hinder the administration of justice. In particular, it is forbidden to induce persons called to make before the judicial authority statements that can be used in criminal proceedings against PY and/or the addressees not to make such statements or to make false ones.


The violation of the principles set forth in this code compromises the relationship of trust between the company and its directors, employees, collaborators, consultants, customers, etc., therefore all violations will be assessed promptly, and possibly countered through the adoption of disciplinary measures that are appropriate and proportionate to the violation, regardless of the possible criminal relevance of such conduct and the institution of criminal proceedings in cases where they constitute a crime.
The content of any measures imposed as a result of the aforementioned violations will comply with the provisions of current legislation, the individual contract and the disciplinary code. The measures may also result in termination of employment and compensation for any damages suffered.


The Code of Ethics is understood to be endorsed by People Yield by its advertisement on
Any future updates of this Code of Ethics, due to regulatory adjustments, the evolution of civil awareness or other, will be promptly communicated to all Recipients.


The Administrator is responsible for ensuring compliance with this Code.
In particular, any violation of the principles and provisions contained in this Code of Ethics must be promptly reported by Certified Electronic Mail (PEC) to


Milan, 14 October 2021