Avviso modifica Condizioni Generali di Contratto Servizi TLC

Informiamo i CLIENTI che CLOUDITALIA ha provveduto ad aggiornare le proprie Condizioni Generali di Contratto dei Servizi TLC adeguandole a quanto imposto dalle Delibere Agcom nn. 348/18/CONS - 133/18/CIR - 487/18/CONS - 347/18/CONS. Trattandosi di modifiche imposte da Leggi e Regolamenti, le nuove Condizioni Generali saranno automaticamente applicate a far data dalla pubblicazione delle stesse sul sito web www.clouditalia.com alla sezione “Area Clienti” il 10/01/2019. Consulta l’informativa di dettaglio e le nuova documentazione contrattuale in “Area Clienti”.

Avviso adeguamento delibera AGCOM n. 348/18/CONS sulla libertà di scelta delle apparecchiature terminali dal 1 dicembre 2018

A partire dal 1 dicembre 2018, in ottemperanza alla Delibera AGCOM n. 348/18/CONS, CLOUDITALIA garantisce ai propri CLIENTI il diritto di utilizzare i dispositivi per l’accesso ad internet (modem, router, access gateway VoIP) di loro scelta. Per la corretta configurazione dei Dispositivi Internet scelti dal CLIENTE, CLOUDITALIA comunica - senza oneri aggiuntivi - le specifiche e i parametri necessari tramite la lettera di attivazione (cd. Welcom Letter) del Servizio e/o accedendo al sito web alla sezione “Area Clienti”.
In adeguamento alla predetta Delibera, CLOUDITALIA, mette a disposizione del CLIENTE sottoscrizioni di offerte in abbinamento con i Dispositivi Internet “a titolo oneroso” e in noleggio prevedendo tale servizio come “opzionale”. Le offerte di servizi integrati prevedono la fornitura del Dispositivo Internet “a titolo gratuito” e in comodato d’uso. In entrambi i casi, le condizioni economiche e tecniche aggiuntive collegate alla fornitura sono indicate nelle Specifiche Tecniche, Descrittive e Tariffarie relative al Servizio di cui trattasi. Coloro che alla data di entrata in vigore delle Condizioni Generali di cui all’avviso che precede usufruiscono di Servizi resi tramite Dispositivo Internet CLOUDITALIA a titolo oneroso e in noleggio, in aderenza alla Delibera n. 348/18/CONS, possono recedere dal servizio opzionale senza oneri diversi dalla mera restituzione del Dispositivo Internet fornito da CLOUDITALIA e scegliere di utilizzare il proprio Dispositivo Internet, laddove tecnicamente possibile.
I servizi di installazione e manutenzione dei Dispositivi Internet scelti dal CLIENTE sono attività anch’esse libere e possono essere liberamente affidate dal CLIENTE a soggetti terzi a proprio onere e a propri costi. CLOUDITALIA non risponde per servizi di installazione e manutenzione, nonché per disservizi che riguardino esclusivamente il funzionamento del Dispositivo Internet scelto dal CLIENTE o che da quest’ultimo derivino, il quale deve rispondere alle esigenze tecniche necessarie alla corretta fruizione dei Servizi. Per maggiori dettagli consulta la FAQ “Come posso utilizzare il mio dispositivo internet?” e la nuova documentazione contrattuale in “Area Clienti”.



The evolution of digital systems is a big opportunity that increases competitiveness, improves both internal and external processes, facilitates and simplifies communication and collaboration among people, groups and organizations. Digital communication and Cloud-based applications instantly make your job easier besides increasing productivity, reducing investments, and increasing your revenues.

Clouditalia is the Telecommunications and Cloud-based integrated services company dedicated to the labour market: companies, professionals and public administration ready to seize the opportunities offered by the constant evolution of both the global market and digital economy.
Our Vision, therefore, is:

  • launching innovative services, especially conceived in order to make both Italian SMEs and the Public Administration more competitive.
  • contributing to the relaunch of the industrial system by facilitating doing business in Italy, making it less expensive and more competitive; particular attention is paid to start-ups and young entrepreneurs who can turn Cloud Computing into their best ally in order to launch their company with fewer costs and increased efficiency"
  • being unique, the only operator in Italy to provide services and solutions in the TLC sector in order to be able to compete with the strongest players. Italian SMEs need a basic TLC with a good level of service; the market, however, has neglected this potential group of clients so far. In addition, Clouditalia needs to return to being a reference partner on the WHS market.


The world of applications and software relies more and more on both telecommunications and the web. The need for mobility makes it necessary to access applications from devices such as smartphones or tablets. Clouditalia adds a special ingredient: an approach based on processes analysis, enabled by an innovative technological platform that allows solving operational problems without having to modify existing software systems. A platform of advanced services is thus created; the browser is its only interface, knowing operational processes is the only requirement for services' set-up and the network is the guarantee of quality and reliability.

In addition, our Mission implies:

  • Working in the Telecommunications sector on the whole Italian territory in the Business, Internet Service Provider and Carriers sector for the Voice, Data and Internet offer.
  • Becoming the main SMEs' provider of TLC and CLOUD-based services with standardized TOP services; offering "Tailored" solutions to our Large Client base and achieving excellence in our services quality as well as in our support network.
  • Designing, building, developing and managing software solutions, both flexible and innovative, that allow our clients to achieve their business goals and that contribute to both creating more value for our shareholders and valuing all our workers.
  • Directing the Company's actions towards the best use of resources, being aware that its economic and social growth are linked to the contribution and participation of all its employees who will be made aware of safety at work and health standards. Top-level management strongly believes that everyone can and must contribute to achieving such goal by tapping into their skills, knowledge, experience and sense of responsibility.
  • Performing corporate activities in a way that meets both Clients' and Third Parties' needs while guaranteeing adequate levels of Information Security.

As for Safety at work, the Company considers WHS as an integral part of the corporate management; each worker, according to their tasks and competences, is responsible for its implementation. Standing out thanks to both the Employer's and top-level management's commitment to spreading and complying with a health and safety system in the workplace.


Clouditalia is committed to:

  • providing its Clients with the best quality of the products/services it offers as well as with the best relationship in compliance with the ISO 9001:2008 requirements
  • guaranteeing the implementation of the norms relating to safety at work
  • guaranteeing the importance of Safety intended as a tool that allows information exchange, by means of:
    • information protection from non-authorized access;
    • information storage and confidentiality;
    • implementation of regulatory and legislative requirements;
    • the guarantee that information will not be disclosed to non-authorized people, whether intentionally or due to negligence;
    • the protection of information integrity from non-authorized changes;
    • information availability, when necessary, to authorized users;
    • the set-up, maintenance and trial of the corporate continuity plans as far as possible;
    • the involvement of the whole staff in information security training;
    • the analysis of criticality and suspected weaknesses of information security.

To respect such commitment, Senior Management accurately monitors all processes besides ensuring that the Integrated Management System is compliant with the reference one. Clouditalia is also committed to:

  • respecting and ensuring the compliance with the laws in force in the States where it runs its activity as well as the ethical principles illustrated in its Code of Ethics and in its WHS policy (Workplace Health and Safety).
  • considering its employees/associates as a strategic resource, thus guaranteeing the respect of their rights, promoting their accountability, participation and professional/personal development and understanding their needs and expectations, making them more aware and training them to perform their tasks safely. The Company is committed to providing both the human and instrumental resources necessary to the policy's success which will be supported by workers' involvement and availability as well as by their safety representatives.
  • considering its suppliers as partners, both from an operational standpoint and by involving them in its ethical path while paying more and more attention to their choice and assessment
  • implementing a system of cooperation, communication and dialogue with all involved Parties, thus allowing them to test the actual ethics and quality of Clouditalia's services
  • managing possible complaints coming from all the involved Parties

Clouditalia is also committed to:

  • scheduling and performing its activity aiming at ensuring safety at work in order to reduce and prevent accidents, injuries and occupational diseases
  • performing risk assessment for each task, activity, premises and plant and to defining protection and prevention measures
  • incentivizing the whole corporate structure to take part in and contribute to achieving the company's goals
  • managing tenders and professional services in order to protect its staff as well as third parties'
  • defining corporate goals that aim at improving corporate health and safety conditions; these will be re-examined, assessed and redefined periodically
  • providing sufficient resources to implement the above-mentioned points.

In order to keep improving, and bearing in mind the foreword, Senior Management defines the following goals:

  • increasing its market position in the Telecommunications sector;
  • developing and attacking the Cloud Computing market;
  • driving the SMEs market with basic TLC/CLOUD-based services at market prices;
  • focusing commercial operations on the areas equipped with proprietor infrastructures by means of geomarketing analysis;
  • maintaining Customer Base TOP Executive and Large with a proactive action aimed at the clients who are more likely to grow, by offering them TLC/CLOUD-based integrated services;
  • directing all efforts towards the improvement of the virtuous cycle service-quality-business development, by tapping into the corporate excellence;
  • continuing business development and the promotion of all the services offered;
  • ensuring the continuous and measurable improvement of corporate performance by means of costs reduction, Resources optimization, the study of new technologies while paying special attention to the ethics of the performance, the organization and the processes, especially the ones that directly influence the quality of both the product and the service always trying to satisfy both internal and external clients;
  • eliminating risks for people's safety by relying on acquired knowledge and technical progress; trying to deal with the source that generated them so as to reduce them as much as possible;
  • replacing everything that may be potentially dangerous with non or less dangerous elements while always paying attention to residual risks;
  • applying ergonomic principles to the workplace, during the design stage as well as in the choice of equipment and in the definition of working methods, in order to reduce both monotony and hardships;
  • prioritizing collective protection measures as well as the respect of individual protection ones and assessing their implementation;
  • focusing health control on the peculiarities of each type of risk;
  • defining and organizing the emergency measures to be adopted in case of first aid, fire fighting,evacuation of workers and in case of immediate and serious danger while also defining possible preventive measures;
  • performing maintenance operations to guarantee that the workplace, the equipment, machinery and plants function properly and are not a source of risk, in compliance with technical, periodical specifications indicated by the manufacturers;
  • providing both the workers and their representatives with information, training and assistance on issues such as safety and health both in the workplace and in the surrounding environment;
  • supporting and motivating its staff for the promotion of ethical principles as well as for those relating to the quality of both products and services; in so doing, internal and external suggestions will be taken into account;
  • defining and organizing all necessary measures to guarantee maximum information confidentiality;
  • defining all necessary measures to guarantee both logical and physical security of corporate assets;
  • defining a backup policy;
  • defining a Business Continuity policy and a Disaster Recovery one;
  • identifying, through careful risk assessment, the value of IT resources in order to understand their vulnerabilities and the threats that may put them at risk;
  • managing risks adequately by designing, implementing and maintaining a formal System for the Management of Information Security;
  • formulating, timely and periodically, a Training Plan for internal staff; this is a necessary activity for the corporate development and growth as well as for the improvement of the Integrated Management System.

Senior Management:

  • appoints the Representative for Quality to whom it gives mandate and authority to perform all necessary actions to define and implement a management system for quality that complies with the reference standards, that is suitable for achieving the goals defined here while favouring improvement through the right activities and initiatives;
  • appoints the Information Security Officer; appoints the Protection and Prevention Officer to whom it confers the responsibilities connected to the task, in compliance with Legislative Decree 9 April 2008 n°81;
  • appoints the Officer in charge of the integrated system for safety;
  • appoints the Representative of the integrated system management for safety;
  • designates, in accordance with RSPP, staff members paying special attention to prevention and emergency teams as well as to the first aid structure;
  • appoints the competent physician when envisaged by legislative provisions;
  • guarantees the respect of the Employer's responsibilities in compliance with Legislative Decree 9 April 2008 n°81.

Senior Management also complies with the Legislation including the following norm in force in the Italian State:

  • Legislative Decree n° 196 of 2003, Code on Personal Data Protection that regulates personal data processing.

  • Attachment B Legislative Decree 196 of 2003 containing the norms for the detection of minimum security measures for personal data processing.

  • Legislative Decree n° 518 of 1992 that amends the Royal Decree n° 633 of 1941 about copyright and integrates it with norms relating to the legal protection of computer programs.

  • Law n° 248 of 2000 that introduces new norms for the protection of copyright.

  • Law n° 547 of 1993 that amends the Italian penal code introducing the so-called "computer crimes".

  • Legislative Decree n° 467 of 2001 containing corrective measures and amendments to the norms relating to personal data protection, pursuant to article 1 of law 24 March 2001, n. 127.

Being compliant with:

  • All the contractual conditions of each client as far as information security is concerned.

  • Resolutions and provisions of the Privacy Authority.

Policy Review

The review of the integrated system considers, among its verification elements, the continuous adjustment of the policy due to corporate changes, as well as the achievement of the goals envisaged by the policy itself. The policy is reviewed annually according to the system monitoring results; appropriate changes are made if necessary; such changes are then communicated in the new document issued.


1 Foreword

CLOUDITALIA Telecomunicazioni S.p.A., a sole shareholder company (hereinafter only "Clouditalia" or the 'Company') is a company that offers a winning, advanced model of communications services and applications that has already been tested by the most competitive businesses in the world; its results include an increased productivity in both the private and the public sector.

Through this model, Clouditalia aims at creating value for its shareholders, thus contributing to the well-being and the professional growth of its employees and associates; it also aims at introducing new innovative elements into the technological sector in full compliance with corporate values.

Clouditalia is formed by highly specialized professionals, with a strong international background, who participated in and directly contributed to the most important technological transformations in the world, achieving important goals next to, as well as leading, the most important businesses in the field.

In pursuing its mission and achieving its goals, Clouditalia is committed to being as transparent and clear as possible at all organizational levels; it shows its commitment by adopting this Code of Ethics that represents a crucial tool.

2 Introduction

This Code of Ethics has been defined in order to guarantee that Clouditalia's main ethic values are clearly established and constitute the basis of corporate culture, as well as the standards of conduct followed by all employees and associates in performing their tasks.

In order to define an efficient and virtuous ethical system, this Code is based on a process of sharing, interiorization and implementation of the principles and values contained therein.

2.1 Recipients and scope

The Recipients of the Code are:

  1. the members of the Board of Directors and of the Board of Statutory Auditors;

  2. top management;

  3. employees;

  4. co-workers and consultants who work for the company

All the activities performed by each Recipient must be inspired by the principles contained in the Code; they must be aware that, when running a business, respecting the ethics is fundamental in order to achieve and maintain high qualitative standards as well as for the success of the company.

To this end, the Recipients shall respect all legislative and regulatory provisions in force in the Countries where they work, as well as the principles of honesty, reliability, impartiality, transparency, fairness and good faith both while pursuing their goals and in order to prevent the crimes referred to in the Legislative Decree 231 of 2001.

2.2 Cogency

The Code of Ethics is binding for all those who cooperate with the Company both directly and indirectly, either permanently or temporarily. The Company is committed to identifying and implementing the most effective tools and interventions to guarantee the spread, knowledge and implementation of the Code of Ethics; it also envisages specific training and information sessions if necessary.

3 Clouditalia's essential ethical principles

Clouditalia's essential ethical principles are:

  1. Legality, honesty and fairness

  2. Impartiality

  3. Transparency

  4. Professionalism and Trust

  5. Prevention of possible conflicts of interests

3.1 Legality, honesty and fairness

Clouditalia is committed to basing its activity on both formal and substantial legitimacy of the norms in force besides acting in full compliance with such norms, the code of ethics, and internal regulations. It also ensures that its decisions are not driven by a personal interest or one that is in contrast with the duties of trust that are at the heart of the corporate role it covers.

3.2 Impartiality

Clouditalia is against all forms of discrimination, whether based on age, gender, race, language, personal or social conditions, religious and political belief. It carries out its activity respecting individuality, promoting the sense of belonging and enhancing professionalism, integrity and the sense of responsibility in accordance with the principles of freedom, human dignity and respect for diversities.

3.3 Transparency

Clouditalia ensures the absolute transparency of each action it undertakes, both internally or at corporate level, on the market; it is committed to providing complete, prompt and truthful information while guaranteeing the transparency of its decisions in a detailed and traceable way. Complete information is provided to all those who will sign agreements or contracts with the company (in any form) so as to communicate their expected behavior clearly.

3.4 Professionalism and Trust

All Clouditalia's co-workers are carefully selected and trained; the company enhances its staff professionalism by facilitating the transfer of knowledge and the sharing of goals and results while respecting personal traits.

Therefore, all co-workers are expected to act honestly, with commitment and respecting the ethics so as to protect both the image and the reputation of the Group at all times.

3.5 Conflicts of interest

In carrying out its activities, Clouditalia tends to avoid situations where the parties involved in the transactions are, or may only appear, in conflict of interest.

Employees and associates must therefore avoid any situation and refrain from any action that could counter a personal and/or family interest with those of the Company or that may interfere with or hinder their ability to take decisions, impartially and objectively, in the Company's interest.

All situations of conflict of interest, even potential or indirect ones, must be promptly reported to the Supervisory Board, which is appointed by the Company, in order to evaluate the existence of the conflict and its severity and to exclude or mitigate its consequences.

3.6 Confidentiality

Recipients shall ensure maximum discretion over any news and information relating either to corporate assets or to Clouditalia's activity, in compliance with the law, regulations in force, this Code and internal procedures.

The company is committed to protecting the information relating to Employees, Directors and Associates, either generated or acquired within the corporate structure and/or through business relationships, and to avoiding any misuse of such information.

4 Principles of conduct

4.1 Relationship with the staff

Clouditalia believes that human resources are a crucial factor for the company's development.

Values such as specialization, skills, promptness and attention to quality in the achievement of goals, are at the heart of the corporate "policy" for the management of the relationship with employees.

The skills evaluation systems adopted by Clouditalia aim at assessing the level of professionalism of its employees meant as an enrichment acquired through work experience, training courses and the results obtained.

Clouditalia enhances the knowledge, skills and the qualities of its employees. In particular:

  1. knowledge refers to the specific one required by the job, to general culture as well as to the organizational knowledge meant as a context of organizational systems and processes within which the company's activity is carried out;

  2. skills relate to professional abilities linked to the work activities;

  3. qualities refer to personal skills that are pivotal both to apply the knowledge possessed and to address one's skills; they are therefore connected to the approach to work adopted and to the performance (realization, determination, autonomy), to the management of organizational relations (being open, positive and reliable) and to a more subjective dimension of individual development and growth (adaptability to change, balance, creativity).

Clouditalia's employee assessment is designed to attest the level of professionalism achieved, always respecting personal characteristics, freedom and equal opportunities; assessment always implies the planning of a further resource development through professional improvement.

Clouditalia judges its employees' contribution according to the corporate goals achieved.

The performance assessment compares the goals set and the ones actually achieved as well as the actions and the tasks performed in a fixed period of time.

4.2 Relationship with collaborators and consultants

Clouditalia selects both its collaborators and its consultants impartially, autonomously and objectively.

All people involved with the company shall act loyally in order to respect both the obligations contracted with the job contract and the Code of Ethics, always ensuring the performance expected. All associates shall work diligently in order to protect corporate assets, by adopting responsible behavior in line with the operational procedures envisaged to regulate their proper use.

4.3 Relationship with authorities and public institutions

Relationship with "institutions", such as the Public Administration, organizations, public bodies, public officials or people in charge of public service and the like, at national, international or local level, as well as with other subjects representing collective interests, are delegated exclusively to people designated by Clouditalia to act on its behalf.

In particular, Clouditalia's agent, in compliance with the principles contained in the Code of Ethics, cannot, in their relations with the representatives of the Public Administration, whether Italian or foreign, directly or indirectly:

  • promise, give money, rewards or presents for purposes other than the institutional ones; gifts or rewards are allowed only when they are of modest value or when they do not compromise the integrity or reputation of either party and when they cannot be considered, by an impartial observer, as aimed at obtaining undue advantages;

  • offer job opportunities that might favor public Administration employees;

  • promise or grant benefits of any type, in order to influence independence of judgement or to obtain any advantage for the Company;

  • behave deceivingly so as to mislead the Public Administration into making a wrong technical-economic evaluation of the products and services offered/provided;

  • allocate contributions, grants, incentives, subsidies or public funds for purposes other than the intended ones.

4.4 Environment, safety and health

Clouditalia is committed to seeking the best results in terms of environmental protection and to complying with the regulations in force, taking all necessary measures for the protection of workplace safety and workers' health, including the prevention of occupational risks, information and training, as well as the provision of the necessary organization and means.

Technological research and innovation should be oriented to the realization and promotion of products and processes that are more environmentally friendly besides being characterized by an ever greater attention to the recipients' safety and health.

4.5 Relationship with both the clients and the suppliers

Relationship with the clients must be based on courtesy and on shared objectives, in the spirit of professionalism, responsibility and integrity. All those who work for or collaborate with Clouditalia must therefore maintain and develop existing relations according to the highest quality standards in order to satisfy the client's reasonable expectations.

The contracts, drawn up in accordance with the laws in force, are characterized by transparency, fairness, completeness and clarity; Clouditalia agrees not to resort to circumvention or unfair practices.

The selection of suppliers, as well as the formulation of the conditions of purchase of goods and services, are based on evaluation procedures inspired by the principles of legality, competition, objectivity, fairness, impartiality, fair price, quality of goods and/or services, by carefully assessing both the guarantees of assistance and the range of offers.

The stipulation of a contract with a supplier must always be based on extremely clear relationships, avoiding, wherever possible, the acceptance of contractual obligations that imply dependence on the contracting supplier.

Procurement processes must aim at obtaining the highest competitive advantage for Clouditalia; they must be fair and equitable to all suppliers who meet the requirements.

4.6 Relationship with the mass media

Due to the importance covered by information for the company's image, relationship with the mass media is based on the compliance with current legislation, internal regulations as well as with the principles of professional correctness. All communication with the mass media is delegated to the functions in charge. The news provided shall be prompt, complete, transparent, truthful and homogeneous.

4.7 Confidential information

Recipients who should be in possession of confidential information concerning the life and activities of the company (acquired while carrying out their task) shall not use it improperly or communicate it to third parties, without justification or Clouditalia's explicit approval.

Recipients are made aware of their confidentiality obligations, especially as far as "price sensitive" information is concerned in order to avoid misuse (in compliance with the national and international norms concerning insider trading) aimed at deriving financial advantages, or any other advantage, influenced or not by unlawful disclosure of information.

4.8 Sensitive data processing and privacy protection

Clouditalia protects personal and sensible data in compliance with the legislation in force. In order to do so, it adopts both technical and organizational solutions to ensure both the security and the confidentiality of the data processed.

Specific security measures are adopted in order to prevent either the loss or unlawful use of the data handled by Clouditalia.

Data protection, as well as the protection of all associated elements, is guaranteed in that the company protects:

  • confidentiality: it ensures that data are accessible only to authorizes staff;

  • integrity: it protects data completeness as well as that relating to their transmission;

  • availability: it ensures that authorized personnel can access data and the related information when necessary.

The lack of an adequate level of data security, in terms of confidentiality, availability and integrity, can result in the loss of competitive advantage, as well as in a loss of image, clients, turnover (which would imply a significant financial loss). In addition, the risk of incurring sanctions due to the violation of the norms in force must be taken into account.

Clouditalia knows and guarantees the importance of its internal IT system as a pivotal requirement for the protection of the information it handles, its reliability as well as the efficiency and the effectiveness of the services it provides. Therefore, its IT system security is obtained through a series of adequate safety measures, or procedures, technical measures or actions aimed at reducing the risks surrounding information assets.

4.9 Assessment and transparency of accounting activities and operations traceability

Clouditalia promotes and guarantees, in compliance with the norms in force as well as with accounting principles, internal regulations and procedures that its accounting records are based on precise, detailed and verifiable information and that they are inspired by the principles of information transparency, accuracy and completeness. To this end, all its associates are expected to act in a way that ensures the completeness of financial documents, risk prevention, reports timeliness, the protection of the activities' value as well as of losses.

Clouditalia expects its accounting-administrative system to be reliable; such system shall represent the management actions correctly in order to prevent and face at best financial and operational risks as well as possible frauds against the company.

The company's auditors must have free access to data, documents and necessary information in order to carry out their tasks.

In addition, all actions and operations performed must be adequately recorded; assessment of the decisions taken, authorization and process performed must be possible. Each operation performed requires an adequate document support in order to be able to assess the features as well as the reasons behind it and in order to identify the person who authorized, performed, recorded and assessed the operation itself.

4.10 Relationship with internal assessment bodies

Clouditalia is committed to spreading, at all corporate levels, a culture inspired by control, characterized by the awareness of both the existence of internal assessment procedures and their contribution to efficiency.

Internal assessment refers to all useful or necessary tools for directing, managing and assessing Clouditalia's activity aiming at ensuring the compliance with corporate laws and procedures, protecting corporate assets, managing activities effectively and providing accurate and complete accounting and financial data..

The Company expects all Recipients to behave in a way that upholds correctness and transparency especially in relation to the requests made by associates, the Statutory Auditors and other social bodies in the exercise of their institutional functions.

5 Violation of the Code of Ethics and sanction system

5.1 Violations and sanctions

Violation of the principles contained in the Code of Ethics will be punished by means of the sanctions envisaged by the Company's Disciplinary System and indicated also in the Organizational Model.

The respect of the Code of Ethics' norms is to be considered as a fundamental part of the contractual obligations of Clouditalia's employees, in accordance with art, 2104 of the Civil Code, as well as of the contractual obligations undertaken by non-subordinate associates and external consultants.

Therefore, all infringements committed by employees, suppliers and external collaborators, as well as by all other subjects having undertaken contractual obligations with the Company, will be interpreted as failure to comply with the main obligations deriving from the work relation or as a disciplinary offence, with all subsequent legal consequences, also in terms of the continuation of the relationship; it may also imply the compensation for damage caused.

Interested subjects can report all violations (in written form and non-anonymously) and/or suspected violations of the Code of Ethics to the Supervisory Board appointed by the Company; this will promptly evaluate the request by contacting the person responsible for the infringement if necessary.

The Supervisory Board shall protect all those who report infringements from retaliation, meant as an act that may be interpreted as discriminating or penalizing. In addition, the identity of the person reporting the violation shall not be disclosed, except when required by law.

6 Final provisions

6.1 Conflicts of the Code of Ethics

In case one of the provisions envisaged by the Code should be in conflict with any other provision contained in the company's regulations or internal procedures, the Code shall prevail.

The Board of Directors, even following communication by the Supervisory Board, shall review the main procedures and policies so that they are compliant with the Code.

6.2 Monitoring, amendments and update of the Code of Ethics

The Code of Ethics shall be reviewed at least annually by Clouditalia's Board of Directors, following the Supervisory Board evaluation.

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