Compliance

Ethics, Transparency, Prevention.

Valuecube adopts a structured governance and control system designed to ensure compliance with applicable regulations, prevent risks, and promote conduct based on ethics, transparency, and accountability.

The company’s compliance framework is built on organizational models, procedures, and control mechanisms aimed at preventing misconduct and ensuring compliance with current regulations and internal standards.

Model 231 and Code of Ethics

Model 231 and Guiding Principles.

Valuecube promotes a management approach based on ethics, transparency, and accountability, in line with its core values and the main reference standards relating to quality, information security, environmental protection, and business continuity.

In this context, Valuecube has adopted an Organization, Management and Control Model pursuant to Italian Legislative Decree No. 231 of June 8, 2001 (“Model 231”), as well as a Code of Ethics, with the aim of preventing the commission of offences covered by the legislation and ensuring fairness and integrity in corporate conduct.

Note:

The Special Sections of the Model 231 and the internal operating procedures are not published for reasons of security and confidentiality and are made available exclusively to internal personnel and authorized recipients.

Supervisory Body (OdV): Role and Confidential Contact Channels

Establishment and Role of the OdV:

To ensure effective oversight of the implementation and compliance with the Organization, Management and Control Model pursuant to Legislative Decree 231/2001, Valuecube has established a Supervisory Body (Organismo di Vigilanza – OdV), vested with independent powers of initiative and control.

The OdV monitors the adequacy and effective implementation of the Model and oversees the assessment of reports concerning unlawful or non-compliant conduct, in coordination with the company’s whistleblowing system.

Confidential Contact Channels of the Supervisory Body (OdV):

Email: odv@valuecuberesearch.com

Whistleblowing

As required by Legislative Decree 231/2001, Valuecube provides dedicated channels for reporting unlawful conduct or conduct that is not compliant with the Code of Ethics and the Organization, Management and Control Model.

Reports are handled in accordance with the principles of confidentiality, protection of the reporting person, and safeguards against any form of retaliation, in compliance with applicable legislation.

Details:

Reports may be submitted by employees, contractors, and third parties who have a relationship with Valuecube.

The following may be reported:

violations of the Code of Ethics;
violations of Model 231;
unlawful conduct, acts, or omissions relevant under Legislative Decree 231/2001 or other applicable regulations.

The reporting system does not cover:

personal complaints, grievances, or claims;
employment disputes that are not related to relevant violations.

Reports are handled by the Supervisory Body (OdV) through:

dedicated platform: https://valuecube.whistleflow.com
email: odv@valuecuberesearch.com (where applicable)

Valuecube ensures:

the confidentiality of the identity of the reporting person, the reported person, and the content of the report;
the protection of personal data;
protection against retaliation, in compliance with applicable legislation.

The possibility of using the external reporting channels provided by law remains unaffected, including those made available by the Italian National Anti-Corruption Authority (ANAC – https://www.anticorruzione.it).

Reporting Near Misses

In line with the prevention principles set out in Legislative Decree 81/2008, Valuecube Research collects reports of near misses, events that could have resulted in an accident or injury but did not actually do so, through the following email address: nearmiss@valuecuberesearch.com

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