CODE OF ETHICS

1. PREFACE
The code of ethics is the main means to spread ethical culture within the Fondazione, as it points out the principles and values to which everybody should adapt their own behaviour. The spread of the code of ethics has been increasing in the latest years, thanks to specific, especially international, laws which led companies and other bodies to adopt them. In Italy, the significance of providing itself with a code of ethics is stressed by the law 231/2001, which envisages a specific reponsibility for bodies in case of crimes.
Therefore, this code of ethics defines ethical tasks and responsibilities in managing business and company activities for the FONDAZIONE TEATRO DELL’OPERA DI ROMA (as henceforth defined) members, for its employees – both managers and non managers – and for anybody, working on behalf of the FONDAZIONE TEATRO DELL’OPERA DI ROMA, collaborating in a fixed term project or in a work experience (henceforth defined as “Collaborators”), who might carry out one of the specified risky activities.
The code of ethics contains a series of principles inspiring all activities and behaviours of the FONDAZIONE TEATRO DELL’OPERA DI ROMA. These must be respected in all applicable norms. Hence, the FONDAZIONE TEATRO DELL’OPERA DI ROMA has decided to adopt its own code of ethics and to make it official part of his internal security system.
1.1 The FONDAZIONE TEATRO DELL’OPERA DI ROMA

The FONDAZIONE TEATRO DELL’OPERA DI ROMA, as legal subject in private law, was established after the transformation of the Teatro dell’Opera into an autonomous body, in compliance with the article 1 of 345 law decree (24 November 2000), which became law on 26 January 2001 (article 6). Its charter members are: the State, Rome City Council and Lazio Region.
The FONDAZIONE TEATRO DELL’OPERA DI ROMA, in the light of the artistic and cultural tradition of Teatro dell’Opera di Roma autonomous body, intends to promote, favour and increase not only education, training, refresher or orientation courses for those who, currently or in the future, are involved in activities linked with culture, music and performing arts, but especially it intends to favour and increase training for artistic and technical managers, by promoting and encouraging all initiatives aimed at enhancing and spreading the knowledge of these disciplines.
2. GENERAL PRINCIPLES

The code of ethics of FONDAZIONE TEATRO DELL’OPERA DI ROMA intends to define a system of rules, which everybody working on behalf of the Fondazione must adhere to. The following people must respect it:
–    the representatives of social bodies and managers, who must conform their behaviours to the code of ethics, spread its knowledge and share it with employees and collaborators;
–    the employees, who must act in compliance with the code and report any infringement.
–    the external collaborators, who must be properly informed of the conduct rules of the code. They must adhere to these rules during the whole collaboration with the FONDAZIONE TEATRO DELL’OPERA DI ROMA.
2.1 FINANCIAL AND CASH FLOW MANAGEMENTThe financial flows must be managed by assuring full tracking of the operations and by maintaining the proper records within the specific limits of liability. It is strictly forbidden to make any operation which might involve the FONDAZIONE TEATRO DELL’OPERA DI ROMA in the possession of stolen goods, money laundering, and use of illicit goods or money.
The FONDAZIONE TEATRO DELL’OPERA DI ROMA make the necessary checks to verify that cash, received and used in the company’s activities, is authentic. Recipients are required to be extremely careful in managing cash to assure that no counterfeit money is either cashed in or spent.

2.2 ETHICAL CRITERIA
In this section, there are all the main ethical criteria recognized by the FONDAZIONE TEATRO DELL’OPERA DI ROMA to affirm its mission. All subjects involved must be refer to them in order to favour the good operation, reliability and reputation of the Fondazione.
a) LegalityThe FONDAZIONE TEATRO DELL’OPERA DI ROMA, in carrying out its activities, acts in compliance with the laws, the contract, all applicable regulations, the code of ethics and all internal procedures.

b) Impartiality
In the decisions affecting the relations with its stakeholders (audience management, work management, suppliers selection and management, relations with the neighboring community and with the institutions representing the latter) the FONDAZIONE TEATRO DELL’OPERA DI ROMA avoids any discrimination based on gender, race, class, nationality, language, religion, political or philosophical opinions, membership of political or Union associations, health or disability, age.
c) Honesty
In carrying out any kind of activity and relation, the collaborators must respect the laws in force, the national labor contract, the individual contract, the code of ethics, the internal rules. Under no circumnstances the alleged pursuit of interests in the benefit of the Fondazione can justify operations which might not be in compliance with a honest conduct.
d) Fairness
In all activities, any situation in which the subjects involved in the transactions might be in conflict of interests must be avoided.
e) Relations with monitoring bodies
The relations with monitoring bodies are inspired by principles of transparency, exhaustiveness, truthfulness and fairness of information. Any information that, in accordance with the laws in force, must be reported to monitoring bodies cannot be omitted or falsified.
f) Confidentiality
The FONDAZIONE TEATRO DELL’OPERA DI ROMA assures the confidentiality of the information it owns and will not search for confidential data, unless in case of explicit and conscious authorization in compliance with the laws in force. The collaborators cannot use confidential information for aims which are not relevant to their own duties.
g) Value of Collaborators
The FONDAZIONE TEATRO DELL’OPERA DI ROMA collaborators are essential for the institution’s success. This is why the FONDAZIONE TEATRO DELL’OPERA DI ROMA protects and promotes the value of its collaborators to maximize the level of satisfaction and enhance their assets of skills. Therefore, in hierarchical relations, the FONDAZIONE TEATRO DELL’OPERA DI ROMA asks that the authority will be executed with fairness and equity, and all behaviours which might prejudice the collaborator’s dignity and professionalism are fobidden.
h) Quality of service
The FONDAZIONE TEATRO DELL’OPERA DI ROMA orients its own activity toward the audience’s satisfaction and safeguard, futher than the appreciation of the collectiity it operates with.
i) Free Market
The FONDAZIONE TEATRO DELL’OPERA DI ROMA safeguards competition and free market.
j) Juvenile Control
The FONDAZIONE TEATRO DELL’OPERA DI ROMA works at constantly control all minor age people who are given in custofy of the Fondazione.
The relations with minor age people must be respectful of moral fairness. Any abuse, both physical and psychological, on young people is stricly forbidden. The maximum commitment is required to safeguard young people’s phychological and physical health in order to prevent any deviance, abuse or commercial exploitation. Young people’s education must be carried out in compliance with models that value ethical and human principles.
k) Possession and spread of pornographic material
The FONDAZIONE TEATRO DELL’OPERA DI ROMA condemns the production, possession and spread with any means of pornographic material involving minor age people.

3. RELATIONS WITH INSTITUTIONS AND PUBLIC COMPANIES
Relations with Public Administration is inspired by the maximum transparency and fairness. In particular, the FONDAZIONE TEATRO DELL’OPERA DI ROMA relates with State, Region Administrations and any other national and foreign local authorities, in compliance with the roles and functions that are bestowed by the law and the statute, and with the greatest collaborative spirit. Relations with representatives of public institutions are limited to the functions which are decided and regularly authorized, striclty in accordance with laws and rules, and they cannot compromise in any way the integrity and the reputation of the institution.
To this end, it is forbidden for anybody working within or on behalf of the FONDAZIONE TEATRO DELL’OPERA DI ROMA to offer, directly or through third parties, money or any other benefits to public officials or people in charge of a public service.
These prohibitions cannot be eluded through donations that, in the form of sponsorship, appointments, consultancies or advertising, have the same illegal purpose previously forbidden. Favours, homages and hospitality towards public officials or people in charge of a ublic service must be always authorized in advance in accordance with the specific procedures of the FONDAZIONE TEATRO DELL’OPERA DI ROMA; these are allowed only if they have small value or can be considered customary, unless they compromise the integrity and reputation of the FONDAZIONE TEATRO DELL’OPERA DI ROMA or influences the independent judgement of the recipient. In any case, these should reported to the Monitoring Body which is provided for the institution, in compliance with the law decree 231/01.
Similarly,managers, employees and collaborators cannot receive gifts or any other benefits, except if these are within the limits of usual courtesy or have small value. In case a manager, employee, collaborator or any other representative of the FONDAZIONE TEATRO DELL’OPERA DI ROMA receives gifts exceeding the aforemontioned limits, s/he must immediately return them, and report it to the Monitoring Body.

4. CONDUCT CODE WITH PRIVATE INSTITUTIONS AND COMPANIES
The FONDAZIONE TEATRO DELL’OPERA DI ROMA favours the developmente of economic sectors involved or represented in its projects. In business relations with private institutions and companies, Union representatives, managers, employees and collaborators must act in compliance with the principles of professional fariness and efficiency. In particular, further than the aformentioned conduct code with Public Institutions, they should provide the interlocutors with all necessary information to consciously evaluate the transactions and to select the counterparties in accordance with principles of reliabilily, professionalism and morality.

4.1 Relations with benefactors and private sponsors
In order to develop its own activities in Italy and abroad, the FONDAZIONE TEATRO DELL’OPERA DI ROMA avails itself also of donations and sponsorships. In the relations with benefactors and sponsors, the FONDAZIONE TEATRO DELL’OPERA DI ROMA shapes its conduct in accordance with the most transparency and fairness.
Benefactors
All resources collected through spontaneous donations or fundraising undertaken by the FONDAZIONE TEATRO DELL’OPERA DI ROMA are used in accordance with criteria of effectiveness and efficiency, by providing benefactors with appropriate information on how received resources are used. The FONDAZIONE TEATRO DELL’OPERA DI ROMA recognizes, if required, the right for benefactors to remain anonymous.
Sponsors
The FONDAZIONE TEATRO DELL’OPERA DI ROMA reserves the right to evaluate in advance the potential sponsors and to accept co-branding and co-marketing collaborations only with subjects whose business and company profile are not in conflict with the Fondazione’s mission and are not damaging for its image. The FONDAZIONE TEATRO DELL’OPERA DI ROMA respects the sponsors’ privacy and manages funds it receives from them in compliance with their recommendations. The FONDAZIONE TEATRO DELL’OPERA DI ROMA provides each potential sponsor with detailed information on the Fondazione itself and on its activities.

5. CONDUCT CODE TO BE ADHERED TO IN THE RELATIONS WITH OTHER INTERLOCUTORS
5.1. Relations with political parties, Unions and associations
The FONDAZIONE TEATRO DELL’OPERA DI ROMA abstains from any kinf of improper pressure, both direct and indirect, on political or unions’ representatives, even in the case it is realized by its own managers, employees and collaborators. The administrators, managers and employees cannot carry out political activities during their working hours or use the Fondazione’s goods or facilities for this purpose; furthermore, they should clarify that their potential political opinions, expressed to third parties, are strictly personal and do not represent the Fondazione’s opinion or orientation.
In the relations with other associations with their own interests (trade categories, local organizations, environmental associations, for instance), managers, employees and collaborators must not pledge or pay money, pledge or personally give payments in kind or any other benefits to promote or favour the Fondazione’s interests. The FONDAZIONE TEATRO DELL’OPERA DI ROMA can satisfy requests of contributions only in case of not-for-profit bodies or associations or if they have a remarkable cultural or charitable value.
Sponsorship activities can deal with social, environmental themes as well as sport, performing, art and culture. In any case, in choosing the proposals, the FONDAZIONE TEATRO DELL’OPERA DI ROMA is especially careful to avoid any personal conflict of interests.

5.2. Relations with the community
The FONDAZIONE TEATRO DELL’OPERA DI ROMA, in carrying out its activities, takes its own responsibilities towards the community, in accordance with solidarity and dialogue with involved parties. The FONDAZIONE TEATRO DELL’OPERA DI ROMA keeps and develops a relationship of trust and continuous dialogue with the involved parties, trying, whenever possible, to inform and involve the latter in the matters concerning them. In its own business, the FONDAZIONE TEATRO DELL’OPERA DI ROMA is inspired by the principle of healthcare and environmental conservation. Finally, the FONDAZIONE TEATRO DELL’OPERA DI ROMA promotes the social, economic and work-related development in accordance with international standards and rights regarding the fundamental rights safeguard, non discrimination, protection of minors, forced-labor ban, safeguard of Unions rights such as health and safety in workplace, working hours and salary.

5.3. Relations with Media
The FONDAZIONE TEATRO DELL’OPERA DI ROMA gives media the fundamental right to transfer information. This is why it manages the relations with its intelocutors in accordance with the principle of transparency and constantly informs all actors, who are directly or indirectly involved in its activities. Further than publishing reguarly the balance sheets in compliance with the law, the FONDAZIONE TEATRO DELL’OPERA DI ROMA makes public, with proper means or by spreading information to media, all useful information to understand the activities it has carried out, the potential effects on the community and the future programmes.
As it is a delicate task, communication activities and spread of information concerning the Fondazione’s activity is reserved exclusively to the functions in charge. Therefore, it is strictly forbidden to all other poeple to spread news concerning the FONDAZIONE TEATRO DELL’OPERA DI ROMA without being granted the permission in advance. Furthermore, all staff must abstain from spreading false or misleading news which might deceive the external community.

5.4. Protection of animals
The presence of animals can be envisaged in performances and shows, but any violent, stressful or disrespectful against their dignity use is forbidden.

6. COLLABORATORS MANAGEMENT POLICY
The FONDAZIONE TEATRO DELL’OPERA DI ROMA favours and gives attention to its collaborators’ professional and personal development.
It provides an accomodating workplace, by stimulating individual professional contributions and involves people in sharing targets and responsibilities in accordance with their roles.
Selection, salary and training policies are inspired by criteria of professionalism, expertise and quality, and refuse any kind of discrimination or pressures aimed at favouring the appointment to people or subjects outside its own free choices.
Based on the same principle, the FONDAZIONE TEATRO DELL’OPERA DI ROMA expects that managers, employees and collaborators act with impartiality, avoid any disparity in treatment and maintain within the workplace a respectful spirit towards individual dignity and personality.
Appointments fully comply with all legal and contractual laws and favour the inclusion of the employee within the workplace.
The FONDAZIONE TEATRO DELL’OPERA DI ROMA assures the confidentiality of information (also) with regard to employees and collaborators.
The FONDAZIONE TEATRO DELL’OPERA DI ROMA does not tolerate any kind of isolation, exploitation or persecution, due to discrimination for personal or working reasons, by any employee or collaborator towards another employee or collaborator. Any kind of sexual harrassment is harshly punished, even by terminating the employment or collaboration.
The FONDAZIONE TEATRO DELL’OPERA DI ROMA is against any kind of discrimination or benefit grant based on race, language, colour, religion, political opinion and membership, nationality, ethnos, age, sex and sexual orientation, marriage, disability of physical aspect, class.
The FONDAZIONE TEATRO DELL’OPERA DI ROMA is against any illegal or child labor relationships or any other illegal conduct against individual personalities. All job relations and collaboration are established under regular contract, signed by both parties. The FONDAZIONE TEATRO DELL’OPERA DI ROMA promotes culture also among its employees and collaborators and value their professionalisms, by supporting their training and by enhancing their specific expertise.

7. RELATIONS WITH PUBLIC
All relations with public aim towards the excellence of production quality and are inspired by the principles of fairness, honesty, professionalism and transparency. Although the FONDAZIONE TEATRO DELL’OPERA DI ROMA assures the impartiality towards the audience and an equal performance of the service for everybody, it reserves the right to give tickets/subscriptions at discount prices in order to favour the approach with the theatre for specific sections of the audience (for instance, special offers for young people, discounts for elderly ones, etc). In compliance with the law in force, all spectators are given appropriate tickets; it is forbidden for third parties without the mandatory tickets to access the Fondazione’s halls. The FONDAZIONE TEATRO DELL’OPERA DI ROMA staff is not authorized to give permission to external people without the appropriate ticket.

8. SUPPLIERS AND PARTERNS’ OBLIGATION WITH REGARD TO CODE OF ETHICS
The FONDAZIONE TEATRO DELL’OPERA DI ROMA informs suppliers and commercial partners of the contents of this code of ethics. Suppliers and commercial partners must subscribe an appropriate statement of knowledge of the principles enclosed in it, must adhere to them in their relations with the FONDAZIONE TEATRO DELL’OPERA DI ROMA and do not act in such a way that the Fondazione, its managers, employees and collaborators are led to violate these principles.

9. BUSINESS MANAGEMENT POLICY
The FONDAZIONE TEATRO DELL’OPERA DI ROMA survey systematically all events related to its business management, by keeping track of all operations to allow the account management, the reconstruction of justification and the identification of responsibilities. In order to provide the business management with all necessary elements to address and verify the management itself in accordance with principles of effectiveness and efficacy, and in complicance with the laws in force, the representatives of internal agencies, managers and all employees must respect the appropriate laws for accounting, in accordance with roles and responsibilities. Furthermore, all members of Unions, managers, employess and collaborators must not use  for personal interests or not relevant for the business management physical and intangible resources, facilities, real estates and information owned by the FONDAZIONE TEATRO DELL’OPERA DI ROMA.
The use of the aforementioned resources is strictly forbidden for responibilities esulating the specific role or for actions which are unfavourable to the Fondazione’s interest.

10. CODE OF ETHICS FULFILLMENT AND MONITORING
a) Communication and training
Internal and external stakeholders are informed of the code of ethics through appropriate communication activities. To assure the correct understanding of the code to all its collaborators, the Staff Management provides and realizes an annual traning project aimed at favouring the konwledge of ethical principles and norms. Training activities can be differentiated in accordance with collaborators’ roles and responsabilities, and for new employees proper induction training programmes are scheduled.
b) Stakeholders’ reports
All FONDAZIONE TEATRO DELL’OPERA DI ROMA stakeholders can report, in writing or online, and in a not anonymous form, all code violations or suspicions of code violation to the Monitoring Body which analyses the report, questioning the author and the responsible of the supposed violation. The Monitoring Body’s duty is to act in order to assure the providers of the report against any kind of reprisal, discrimination or vitimization. The identity of the provider of the report remains confidential, except any legal obligation.
c) Code of Ethics Violations
The rules of this code of ethics are an essential part of the contractual obligations both for the FONDAZIONE TEATRO DELL’OPERA DI ROMA employees and the Fondazione’s collaborators with regard to their current contract.
The FONDAZIONE TEATRO DELL’OPERA DI ROMA envisages, with coherence, impartiality and uniformity, sanctions which are proportionated to the specific code of ethics violations and in compliance with the laws in force concerning the regulamentation of job relations. In particular, in case of code of ethics violations by the Fondazione’s employees, the relevant measures will be adopted and the relevant sanctions will be inflicted in compliance with the article 7 of the law 300 (20 May 1970) and with what has been established by the current collective barganing.
For the single punishable infractions and the relevant inflictable sanctions, please refer to the Disciplinary Code, which is posted in a place which can be accessed by everybody, in compliance with the current national labour contract and legal norms. The disciplinary relevance of the behavioural norms enclosed in this code of ethics is set forth in accordance with 231/01 law decree; the Monitoring Body must be informed with regard to any measure adopted following reported violations of this code of ethics.

11. SAFETY AND HYGIENE SAFEGUARD IN THE WORKPLACE
The FONDAZIONE TEATRO DELL’OPERA DI ROMA spreads and consolidates a safety culture, by enhancing the awareness of risks, by promoting responsible behaviours on staff and by operating to safeguard, especially through preventive measures, staff’s health and safety. The activities of FONDAZIONE TEATRO DELL’OPERA DI ROMA must be carried out in full compliance with the current laws in force concerning prevention and safeguard; operations management should refer to advanced criteria of environmental protection and energy efficiency, pursuing the improvement of health and safety conditions in the workplace. Facilities and job methods must be conceived by taking into account the level of technical evolution.

12. INFORMATION SYSTEM MANAGEMENT
The FONDAZIONE TEATRO DELL’OPERA DI ROMA strictly forbids the recipients of this code of ethics alterating and/or modifying in any way the operaion of an information or online system or intervening without any right on the data, information or softwares present on one of the aforementioned systems.

13. AUTHOR’S RIGHTS PROTECTION
The FONDAZIONE TEATRO DELL’OPERA DI ROMA strictly forbids the recipients of this code to use in any form and/or way or at any purpose, even for personal use, original works and/or materials protected by author’s rights and/or related to the latter, or by intellectual property (among these, in particular, trademarks, industrial design rights, patent, utility model and trade secrets), including image rights and naming rights, without the consent of rights owners and/or those who have the legal availability. The recipients of this code of ethics must make every effort to ask the appropriate consent to use protected works and materials.

14. SANCTIONS
This code of ethics represents the statutory source in the working relations with the FONDAZIONE TEATRO DELL’OPERA DI ROMA; therefore any violation involves the adoption of disciplinary measures, proportioned to the seriousness of the violation, to the possible relevance of recidivism, to the presence of malice, crime and its degree, in compliance with the norms enclosed in the applicable labour contracts (in Italy, the article 7 of law 300 (20 May 1970).

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