SOP

INFORMATION NOTE UNDER THE TERMS AND TO ALL EFFECTS OF ART. 13 OF LEGISLATIVE DECREE NO. 196 OF 30 JUNE 2003

SOP srl., which processes all the information received from the www.sopgroup.com website and any services connected to it, protects the personal data and information received, in compliance with the provisions of the Italian Legislative Decree no. 196/2003 – Privacy Law, in relation to the safeguarding of privacy and the protection of personal data.

In accordance with and to all effects of art. 13 Decree Law 196/2003, it must be made clear that the access and consultation of the website leads to the automatic registration of the following data:

internet domain and IP protocol address
Browser type and computer operating system used
date, hour and time spent on the website
pages visited
any research engines which were used to find the website.

This data may not in any way identify the user.

This automatically collected information may be used by SOP:

in the case of a suspect use in violation of the laws in force
for statistical purposes
to improve surfing and the content of the website.

The holder of the treatment of personal data is SOP Srl. with registered office in Via Parco Alto Milanese, 1 – 21052 Busto Arsizio (VA) Italy.

CONDITIONS OF USE

These conditions of use regulate access to the web pages of website www.sopgroup.com and the fruition of all services which may be connected to such access. These are subject to variations by SOP. Here follow the terms of a legal agreement between the user of this website and SOP; accessing and/or using this website, the user implicitly declares to have read, understood and accepted the conditions of use; he declares, furthermore, to observe all the laws and regulations applicable, including those regarding exportation and re-exportation. If the conditions of use below are not accepted, the website may not be accessed.

1. COPYRIGHT

All contents, trademarks, logos, icons, texts, etc. of this website are the property of SOP, are disciplined and protected by the Italian and international laws on authors’ rights and have been correctly registered.
All rights are reserved.
No part of this website may be reproduced, transmitted or copied in any way without previous written authorisation from SOP, except in the case of the utilisation of the information for its intended use.
The user recognises and accepts that the websites accessible via the website www.sopgroup.com through links, may be third parties and independent to the SOP website and company. Therefore, no guarantees can be made or responsibilities taken concerning the existence or content of the websites accessed via links.

2. USE OF THE WEBSITE

The website may be used to propose services and commercial offers regarding SOP’s activity and may not be used to send material which is pornographic or anything that may be contrary to public modesty or intended for illicit ends.
The reproduction, modification, duplication, sale and use of the website for commercial aims by subjects not explicitly authorised by SOP, is severely prohibited.
Printing and/or copying contents of the website for personal, and not commercial or lucrative use, is allowed.
Quotations may be taken for news, studies, criticism or reviews, as long as they are accompanied by an indication of the source (www.sopgroup.com) and the name of the author, if dealing with articles.
Any unauthorised use of the website and material and/or information contained in it, constitutes a violation of the laws in force concerning intellectual property.
The user declares that he will follow all the indications regarding trademarks and author’s rights present in downloaded or copied material. The use of this material on any other website is prohibited.

3. DATA SECURITY

SOP checks the network traffic, for the security of the website, to identify unauthorised contacts, other causes of damage to the website and avoid modifications to information.
Any unauthorised activity or the use of this website for other ends and/or purposes is prohibited and punishable by law. If SOP should ascertain a possible violation of law or any criminal activity, the competent bodies will immediately be informed.

4. EXCLUSION OF GUARANTEES AND RESPONSIBILITY

SOP declares that it will ensure that the contents of this website are elaborated with the maximum care and are regularly updated.

Notwithstanding the above, it is possible that errors, inexactness, omissions or momentary malfunctions of some areas of the website occur. SOP declines all responsibility for any errors inexactness, omissions on the website or malfunction of it. SOP does not assume any responsibility for the accuracy, completeness of information, products or processes, including that of being virus free and that the use of information, products, or processes may violate the private rights of the customer.
SOP is in no case responsible for any damage that may be derived from the use of the website, including direct or indirect, accidental and consequential damage.

5. REGULATING LAWS

The General Conditions are regulated and disciplined by the Italian law.

6. MODIFICATIONS TO THE GENERAL CONDITIONS

SOP reserves the right to modify the website and these General Conditions at any time.

Decree Law no. 196/03 — PRIVACY LAW

Every day, a large amount of information is collected regarding all of us; this information may be used to carry out market research, to send advertisements via post, but also for other more or less legitimate ends.

It is, therefore, evident that laws are necessary which control this collection, elaboration, diffusion, communication to third parties, the transfer abroad of this information and the ultimate disposal of the data, when it is no longer useful.

Following a European Directive, Italy published Law no. 675, in 1996, which introduced:

a type of “ownership right” in favour of the interested party
a series of requirements for all those who collect and deal with this data, both in an automatic and manual way.

Since the publication of this law, the matter was subjected to continuous evolution with the publication of numerous legislative measures and interpretive documents, until the government decided to collect the various regulations on the subject in a single document.

This document, called “Code in matter of protection of personal data”, was published as Decree law 196/03; which is divided into three parts:

general regulations
treatment of specific sectors;
safeguarding the interested party and penal and administrative sanctions

The regulations are of a general nature and require, therefore, that the company and organisation defines suitable rules regarding the management of the data, both on paper and in an electronic form.

CODE OF ETHICS

SOP has defined the following code of ethics, which sets out the principles and rules within which to develop the company politics.

A) MORAL INTEGRITY
Moral integrity is the foundation for a trusting relationship with the customer. Following this assumption, SOP declares that it will:

respect the law
work honestly, with diligence and with a sense of responsibility
not accept responsibilities or fulfil requests which may involve the company in illegal activities or doubtful morality.

B) COMPETENCE
SOP understands the importance of providing services which fulfil the customer’s expectations and the highest market standards; to this aim, SOP declares that it will:

only provide services for which it has the necessary know-how and experience to fulfil
continuously update its knowledge and skills through continuous professional training in order to maintain its professional competence at a high level
aim to constantly improve the quality of its services.

C) PRIVACY
Depending on the type of request received from the customer, SOP will have access to reserved information, the incorrect use of which may have quite relevant negative consequences; consequently SOP declares that it will:

treat the information and any documents that come into its possession through the relationship with its customer with the greatest care
use such information correctly, avoiding its unsuitable divulgence which may damage the customer or other parties involved
not use such information to its own personal advantage.

D) OBJECTIVITY
In all cases where an evaluation is required, it must be made using the highest level of professional objectivity; to this end, SOP declares that it will:

carefully formulate its judgement, making the basis of knowledge and competence on which it is founded adequately clear to the interested parties
avoid that any situations where there is a conflict of interests, even potential, compromise, in any way, SOP’s sense of judgement.

E) SUSTAINABILITY
The sustainability of the proposed solutions, in the field of the professional services offered, is an essential element in:

maintaining adequate professional dignity
helping the customer to develop its initiatives in a correct way, respecting ethical values.

To achieve such results, SOP declares that it will exclude from any proposals made to the customer:

any form of under-age or forced labour
any situation:
- which discriminates or which damages the personal dignity of the workers
- which violates the rights of the workers to a free trade union
- which is characterised by excessively long working hours or conditions of payment which are not adequate for the lives of the workers
processes and working procedures which may determine working conditions that are not safe and healthy
processes and working procedures which may result in damage to the environment.

Busto Arsizio 01/10/2008
President of the Board of Administrators and CEO
Marco Poggianella