1    SCOPE AND FIELD OF APPLICATION
Identification and adoption of the values on which a company bases its capacity as a competitive player in its business sector and a responsible entity in the social context within which it operates are key elements in building a corporate culture suitable to achieve the company's objectives.
In this respect, Colliers International Italia SpA has deemed it appropriate to define and formalise this Code of Conduct as the set of rules, values and principles adopted and considered to be important.
The Code of Conduct (hereinafter, “Code”) is an integral part of the company guidelines defined in order to optimise the management of activities, in accordance with the following standards:
i.    providing high-quality services,
ii.    protecting health and safety within the workplace, in accordance with the applicable regulations,
iii.    management of company risks in order to avoid negative repercussions on Colliers International Italia SpA.
Colliers International Italia SpA considers this Code as a tool to regulate and control its activities. Consequently, all employees and collaborators, regardless of their position or status, are responsible for their actions pursuant to this Code, to the Company’s policies and to the applicable legislation.  
Compliance with the Code is an integral part of the contractual obligations adopted by employees, pursuant to and in accordance with art. 2104 of the Italian Civil Code. Therefore, violation of the regulations under this Code jeopardises the relationship of trust established with companies of the Group and may lead to legal action, as well as to the adoption of measures against its recipients, in accordance with the provisions of the law and with the contractual regulations, along with any resulting personal liability.
For these reasons, aware of the importance of this issue as part of its activities, Colliers International Italia SpA has adopted this Code as a charter of rights and moral duties to be respected, without exception, by all employees and collaborators of the Company (corporate bodies and their members, directors, employees, consultants, partners, and suppliers) in both internal and external relations and in order to achieve the corporate mission.

2    GENERAL PRINCIPLES
2.1    COMPLIANCE WITH REGULATIONS

Colliers International Italia SpA agrees to conduct its activities in accordance with community and national regulations, avoiding corruption, money laundering and any other illegal practice.
Pursuit of an interest by the Company may under no circumstance be considered as an exempting justification for non-compliance with the law, nor may it justify any dishonest conduct.
Members of the corporate governance bodies, company management and employees and collaborators of the Company in general are required to diligently respect the regulations in force, this Code, the company procedures and the internal regulations as part of their professional activities.

2.2    RISK CULTURE
The Company aims to instil in its employees sensitivity to the risks underlying their daily operations, disseminating the perception of how the internal control system concretely oversees these risks without any overlapping or gaps.

2.3    IMPARTIALITY
The Company considers impartiality as a fundamental value in its internal and external relationships, rejecting, opposing and punishing any discrimination with respect to the age, gender, sexual preference, health, race, nationality, political views and/or religious beliefs of its interlocutors in every decision-making aspect and/or relationship.
In performing their respective professional tasks, members of the corporate governance bodies, company management and employees and collaborators of the company must respect the principle of impartiality, avoiding the preference or favouring of persons or solutions not based on technical-professional evaluations.

2.4    PROTECTION AND SAFETY IN THE WORKPLACE
Colliers International Italia SpA puts forth the upmost commitment in respecting the regulations in force in terms of safety in the workplace and in striving to protect the health and safety of workers, particularly through preventive action. Furthermore, smoking is prohibited in all areas of the Company, as envisaged by the relative legislation in force.
In this respect, the internal structure, aware of the evolution of reference contexts and the consequent changes in risks, implements technical and organisational measures through:
a.    introduction of a system for the management of risk and safety;  
b.    continuous analysis of risk and of the critical aspects of the processes and resources to be protected;
c.    adoption of the best solutions, methods and timing.

2.5    TRANSPARENCY, CONFIDENTIALITY AND PROTECTION OF PRIVACY
Colliers International Italia SpA and its collaborators agree to provide complete, transparent, comprehensible and accurate information, so that those dealing with the Company are in a position to make independent and knowledgeable decisions, with awareness of the interests involved and of any significant consequences.
Colliers International Italia SpA also ensures the utmost confidentiality of the information in its possession and refrains from seeking out confidential data, except in cases of express authorisation by the interested party and in accordance with the legal regulations in force. Employees and collaborators of the Company are required to maintain the strictest confidentiality as regards confidential information acquired from clients or through their position, and may not disclose said information to third parties or make improper use of it.
The privacy of collaborators and clients is protected by adopting standards that specify the information requested by the Company from them and the relative processing and storage methods, excluding any inquiries as to the ideas, preferences, personal tastes and private life of said collaborators and clients. These standards also prohibit, except in the cases envisaged by law, communication/disclosure of the personal data without prior consent by the interested party, and they establish the rules for monitoring of the privacy protection regulations by each party. In the processing of sensitive data, Colliers International Italia SpA adopts all of the necessary precautions and provisions required by law, pursuant to Italian Legislative Decree 196 of 2003.

3    RULES OF CONDUCT IN INTERNAL RELATIONS
3.1    DILIGENCE, EFFICIENCY AND PROFESSIONALISM
Colliers International Italia SpA considers the providing of high-quality services in each sector of its business to be of fundamental importance.
In this respect, the activities of the Company’s employees and collaborators must be carried out with the utmost diligence, courtesy, accuracy and professionalism. Each work activity must be carried out with a view to cost awareness in terms of operations and efficiency in the use of resources, keeping the common work areas presentable and the tools received/assigned in acceptable condition for the entire duration of their use.
Company personnel are also required to inform Management of any event that could impact or jeopardise the diligence, efficiency or professionalism of their conduct (for e.g., family conditions), in accordance with the current regulations on privacy.

3.2    INTERNAL CONTROL
Colliers International Italia SpA promotes the dissemination of a control culture and makes its employees aware of the importance of control systems and of respect of the current regulations and internal procedures by all employees and collaborators in carrying out the company's activities.  
The Company ensures that the organisation and activities of those responsible for internal control are carried out in full autonomy and in respect of the principles of confidentiality, independence and accuracy, as well as of those contained in this Code.
The Company’s employees and collaborators are required to contribute to proper and efficient functioning of the internal control system, playing an active role in making suggestions for improvement and identifying requirements for adaptation of the company regulations or deviations from the procedures defined.

3.3    CONFLICT OF INTEREST
In conducting any activity, each party involved must avoid conflict between their personal, social, financial or political interests and the development of the business interests of the Company or its clients.
Any employees who are in a conflict of interest position with respect to specific evaluations or actions relating to their duties must inform their supervisors, who will evaluate the most appropriate action in order to resolve and manage the issue. The same requirement is applied to members of the corporate governance bodies, to company management and to collaborators in general.

4    RULES OF CONDUCT IN EXTERNAL RELATIONS
4.1    CLIENT RELATIONS
Colliers International Italia SpA considers it essential to maintain high quality standards in its services.
In dealing with clients, each employee or collaborator is required to adapt their conduct to the criteria of fairness, courtesy and availability, providing, where requested or necessary, complete and adequate information and avoiding any practices that are evasive, improper or in any way aimed at undermining the objective judgment of the interlocutor.  
The Company considers transparency and clarity as key elements of the communication system in place with clients and, in this respect, develops and implements marketing strategies aimed at ensuring that advertising and promotion are carried out in a responsible manner.
More specifically, it aims to ensure that any advertising or promotion carried out:
-    is compliant with national laws and with the laws of the European Community;
-    is not false, misleading or deceptive.

4.2    RELATIONS WITH SUPPLIERS AND OUTSOURCERS
Colliers International Italia SpA applies the utmost transparency and fairness in its relations with the suppliers of goods and services, in accordance with the laws and regulations in force and with its own internal regulations.
It is Company policy to negotiate in good faith and in a transparent manner with all potential suppliers/outsourcers, as well as to avoid even only the appearance of carrying out unjustly partial negotiations or any other action backed by favouritisms or dictated by the certainty or hope of obtaining advantages, even with respect to situations outside of the supply relationship, for oneself or for the Company.
In particular, employees in charge of relations with the Company’s suppliers/outsourcers must not preclude anyone in possession of the required characteristics from competing in the stipulation of contracts, adopting objective and traceable criteria in its selection of the short list of candidates.
Stipulation of a contract with a supplier must always be based on extremely clear relationships, avoiding any form of dependence.

4.3    RELATIONS WITH PUBLIC AUTHORITIES
In its relations with Public Administration or with entities that carry out functions of public utility or public interest, the Company fully respects the applicable community, national and company regulations.
Management of relations of any kind with Public Administration, public officials or parties responsible for public service may be exercised exclusively by authorised parties and must respect the principles under this Code.
All recipients of this Code are required to refrain from:
-    offering work opportunities or any advantage in favour of the public official involved in the relationship, the official’s family members or parties in any way connected to said official;
-    offering said parties gifts, giveaways or benefits, even through third parties, except for acts of courtesy of moderate value;
-    promising or requesting the promise of other forms of benefits or advantage;
-    improperly influencing, also through third parties, the decisions of the institution involved.
If the Company is involved in legal disputes at the civil, penal or administrative level, even on an out-of-court basis, the corporate bodies, employees and consultants must under no circumstance adopt behaviours that could lead to provisions that illegitimately provide an advantage to the Company.
The Company also requires that the corporate bodies and their members, employees, consultants, collaborators and any others acting in the name and on behalf of the Company operate with the utmost willingness and transparency with respect to those carrying out inspections and controls legitimately authorised by the relevant Authorities.
Any individuals who are the subject of inquiries or inspections, for work-related issues as well as for personal issues, or who receive subpoenas, and/or those who are served other legal summons, are required to inform Management.

4.4    RELATIONS WITH POLITICAL ORGANISATIONS AND UNIONS
Colliers International Italia SpA does not make contributions of any kind, directly or indirectly, to political parties, movements, committees or political or union organisations, or to their representatives or candidates, except in the form and according to the methods envisaged by the regulations in force.

4.5    GIFTS AND GIVEAWAYS
No gifts of any type are permitted (donations, advantages or any other benefits) if these go beyond normal business practices or courtesy or are in any case aimed at acquiring favourable treatment in conducting any activity connected to Colliers International Italia SpA.