Club Code of Ethics

in accordance with Legislative Decree 231/2001

General principles 

The Code of Ethics of F.C. COMO WOMEN Srl (hereinafter the "Company"), a company for the practice of football activity, identifies the company values, highlighting the set of rights, duties, and responsibilities of the subjects addressed by the Code itself. The adoption of this Code of Ethics is an expression of a corporate context where the primary objective is to meet, in the best possible way, the needs and expectations of the Company's interlocutors, aiming to recommend and promote a high standard of professionalism in the performance of sports activities and all activities related to the Company, and to prohibit behaviors that are not only in contrast with the relevant regulatory provisions but also with the values that the Company intends to promote. 

In particular, a primary value for the Company is the observance of sports ethics, understood as honesty, loyalty, fairness, and compliance with the laws.  

Recipients

Recipients This Code of Ethics applies to:

• Administrators, Auditors, Executives, and Employees of the Company, including non-traditional workers, professional players, and all members, wherever they operate, both in Italy and abroad;
• External collaborators and consultants acting in the interest and/or on behalf of the Company;
• Individuals or legal entities carrying out activities, works, or services in the interest and/or on behalf of the Company, based on contracts for subcontracting, services, or supplies. Recipients are specifically required to comply with the principles stated therein and sector regulations in carrying out sports activities and in relationships with sports associations, leagues, and federations, both national and international.

The Recipients are specifically required to respect the principles stated therein and the sector regulations, in carrying out sports activities and in relationships with sports associations, leagues, and federations, both national and international.

Duties and responsibilities 

Work relationships among employees must be conducted according to principles of civil coexistence, with mutual respect and ensuring the protection of the rights and freedoms of individuals. 

Relationships between different hierarchical positions within the Company must be based on principles of loyalty and fairness. Furthermore, office confidentiality must be ensured in carrying out activities within one's competence. 

Those responsible for individual activities must exercise the powers delegated to them, respecting and ensuring the dignity of their collaborators and promoting their professional growth. 

Every manager is required to value the working time of their collaborators, requesting performances consistent with the tasks performed by each individual and with the work organization plans. 

It constitutes an abuse of authority to request performances, personal favors, or any other activities and/or behaviors that constitute a violation of this Code of Ethics. 

Company executives, partners, and members are prohibited from engaging in any activities related to the transfer, assignment of contracts, and registration of players and coaches unless it is in the exclusive interest of the Company and in full compliance with applicable sports regulations. 

Additionally, it is prohibited to engage with or have contacts with intermediaries, player agents, or registered players who are banned or disqualified

In relationships with players, registered individuals, intermediaries, or player agents, it is prohibited to enter into contracts not allowed by current sports regulations and/or to provide unjustified compensation, rewards, or allowances, or in violation of current sports regulations. It is forbidden to alter the course and/or the outcome of sports competitions, by any means or method. It is prohibited to place or accept bets, directly or through a third party, even with authorized entities, as well as to facilitate bets by others, concerning the results of official and unofficial matches in which the Company participates and organized within the framework of FIFA, UEFA, and FIGC. It is mandatory to comply with the rules on the correct use and administration of drugs, in accordance with national and international regulations on anti-doping, for the protection of players' health and the fairness of sports competitions.

It is mandatory to comply with the rules on the correct use and administration of drugs, in accordance with national and international regulations on anti-doping, for the safeguarding of the players' health and the fairness of sports competitions. In carrying out the assigned functions, situations that may give rise to conflicts of interest must be avoided. 

To this end, administrators must comply with the obligations set forth in Article 2391, first paragraph, of the Civil Code. Therefore, an administrator who, in a specific transaction, has an interest conflicting with that of the Company, whether on their own behalf or on behalf of third parties, must inform the other administrators and the board of statutory auditors, and must abstain from participating in the deliberations concerning the transaction.

The company's employees must avoid situations that may create conflicts of interest, both real and potential, between personal and business activities: transparency, trust, and integrity are values that must be respected in all cases. No employee of the Company can obtain personal benefits related to the activities carried out on behalf of the Company. In cases where potential conflicts may arise, it is mandatory to report them to their superior for resolution. In relations with the fans, the Company commits to promoting fair and responsible support. To this end, it is prohibited to contribute, financially, to the establishment and maintenance of groups, organized or not, of their fans. The Company undertakes to prevent the introduction and use of pyrotechnic materials, tools/objects capable of causing harm, writings or symbols bearing obscene, offensive, or inciting violence and xenophobia expressions in sports facilities.

It is prohibited for the managers, members, and affiliated individuals of the Company to make statements, through the media, that may incite violence and discrimination, or constitute their apology. It is prohibited for the managers, members, and affiliated individuals to publicly express statements or judgments that damage the reputation of other individuals, entities, and other Companies. Any conduct that directly or indirectly involves offense, denigration based on race, color, religion, language, gender, nationality, origin, or constitutes prohibited ideological propaganda by law, or in any case, promotes discriminatory behavior, is prohibited.

Company information: use and protection

The confidentiality of information is a valuable asset that the Company also protects through its employees. Data concerning individuals will be treated in compliance with current regulations. All Recipients of this Code of Ethics are required to ensure maximum confidentiality regarding the information managed in relation to their work function. Those who become aware of non-public information must use the utmost caution and care in using such information, avoiding its disclosure to unauthorized persons, both within and outside the company. 

Relationships with Public Administration

It is prohibited to give, offer, or promise money or other benefits, such as services, performances, or favors that could reasonably be interpreted as exceeding normal courtesy practices, or to exert undue pressure on public officials, public service agents, executives, officials, or employees of the Public Administration or entities granted public service concessions or their relatives or cohabitants, both Italian and foreign, aimed at inducing the counterparty to perform any act contrary to or in accordance with the duties of their office. 

In dealings with the Public Administration or with public service concessionaires, the Company should not be represented by third parties when conflicts of interest may arise. In the course of commercial relationships with the Public Administration or public service concessionaires, recipients must refrain from soliciting or obtaining confidential information that could compromise the integrity or reputation of both parties.

It is not allowed to make untrue statements to public, national, or community bodies in order to obtain public grants, contributions, or facilitated financing, or to obtain concessions, authorizations, licenses, or other administrative acts. It is prohibited to allocate sums received from public, national, or community bodies, as grants, contributions, or financing, for purposes other than those for which they were assigned. It is forbidden to alter the functioning of an information technology or telematic system of the Public Administration or manipulate the data contained therein in order to obtain an unjust profit.

Relationships with federal, national, and international bodies or with subjects appointed by them

In dealings with federal bodies, by way of example but not limited to (LNP, LND, FIGC and all its components and bodies of sports supervision and justice), the AIA and its members, or with subjects appointed by them, it is prohibited to give, offer, or promise money or other benefits, such as services, performances, or favors that could reasonably be interpreted as exceeding normal courtesy practices, or exert undue pressure in order to improperly influence the decisions of the other party. In dealings with the aforementioned bodies or subjects appointed by them, the Company must not be represented by third parties when conflicts of interest may arise. 

Relationships with the Judiciary Authority and with the bodies of Sports Justice It is prohibited to exert any form of influence on the person called to make statements before the Judiciary Authority or the bodies of Sports Justice in order to induce them not to make statements or to make false statements. 

It is prohibited to help anyone who has committed a criminally relevant act or an act relevant under the scope of Sports Justice to evade the investigations of the authority or to avoid being searched by it. It is forbidden to give or request from third parties information regarding facts subject to judicial or disciplinary proceedings involving the Society.

Relationships with the press and other mass media outlets

The Company addresses the press and mass media outlets solely through corporate bodies and delegated corporate functions, in an attitude of utmost correctness, availability, and transparency, in accordance with the communication policy defined by the Company. Recipients are required not to provide information to media outlets without specific and prior authorization from the competent functions. In any case, information and communications related to the Company and intended for external parties must be accurate, truthful, complete, transparent, consistent with each other, and not contrary to the principles stated.

Recordings, accounting records, and offenses in corporate matters All actions and operations of the Company must be adequately recorded, and it must be possible to verify ex post the decision-making, authorization, and execution process. Each operation must have adequate documentary support in order to proceed at any time with checks that confirm the characteristics and motivations of the operation and identify the individuals who authorized, carried out, recorded, and verified the same operation. Accounting records must be kept accurately, completely, and promptly in accordance with company accounting procedures, in order to provide a faithful representation of the financial position/activity of management. All employees involved in accounting records must ensure maximum collaboration, completeness, and clarity of the information provided, as well as the accuracy of the data and processing. Accounting records refer to all documentation that numerically represents management facts, including internal expense reimbursement notes.

The financial statements and social communications required by law and special regulations applicable to football clubs must be prepared clearly and accurately represent the financial position of the company. Reports, communications, and filings with the Companies Register that are mandatory for the Company must be made by the subjects identified by the laws in a timely, truthful manner, and in compliance with current regulations. 

It is expressly prohibited to prevent or hinder, through the concealment of documents or other suitable devices, the performance of control activities or legal review activities legally attributed to shareholders, other corporate bodies, or audit firms. It is prohibited to engage in simulated or otherwise fraudulent conduct aimed at determining the majority in the assembly. 

It is also prohibited to report to public supervisory authorities material facts that do not correspond to the truth, even if subject to evaluation, regarding the economic, financial, or asset situation of the Company, or to omit the representation of facts that one is obliged to communicate.

This principle must also be observed in relation to information concerning assets owned or administered on behalf of third parties. It is, however, prohibited to obstruct, in any form, the functions of public supervisory authorities and sports supervisory authorities in the context of inspections and/or inspections. It is prohibited, even through concealed conduct, to return contributions made by shareholders or release them from the obligation to make them, outside the cases of legitimate reduction of the share capital. It is prohibited to distribute profits or advances on profits not actually earned or destined for reserves or to distribute unavailable reserves. It is prohibited to reduce the share capital, merge, or split in violation of legal provisions protecting creditors. It is prohibited to fictitiously form or increase the capital of companies, by attributing shares or quotas for an amount lower than their nominal value, mutual subscription of shares or quotas, significant overvaluation of contributions of assets in kind or credits, or of the company's assets in case of transformation. Any operation that may cause harm to shareholders or creditors is prohibited. 

Relationships with partners and suppliers

The selection of contractual and commercial partners is guided by principles of prudence and proper identification, in order to avoid establishing business relationships with individuals directly or indirectly involved in illicit activities such as terrorism, human trafficking, arms and drug trafficking, exploitation and facilitation of illegal immigration, and money laundering. To this end, before concluding any type of agreement or transaction, the Company will gather all necessary information for a correct and truthful identification of its counterparts and/or the individuals to whom they are related, reserving the right to terminate negotiations or withdraw from established relationships if there are elements indicating or reasonably suspecting involvement with the aforementioned illicit activities. The choice of suppliers and the purchase of goods and services are also carried out by the appropriate company functions based on objective evaluations regarding competitiveness, quality, cost-effectiveness, price, and integrity. The Company also reserves the contractual right to adopt any suitable measure (including contract termination) in the event that the supplier, while conducting activities on behalf of the company, violates legal norms or the Code.

Contributions and patronages

The Company may adhere to requests for contributions limited to proposals from non-profit entities and associations that are duly constituted, have a high cultural or charitable value. Sponsorship activities, which may involve social, environmental, sports, entertainment, and art themes, are only intended for events that offer a guarantee of quality or for which the Company can collaborate in the design, ensuring originality and effectiveness. In any case, in choosing which proposals to adhere to, the Company pays particular attention to any possible conflicts of interest of a personal or corporate nature (for example, relationships with the parties involved or ties to organizations that may, due to the tasks they perform, somehow favor the Company's activities).

Human resources management

The Company undertakes to hire personnel with regular employment contracts, in line with the professional figures of the various business areas and in compliance with current federal regulations and the principles of the Civil Code and the Workers' Statute. No form of "black work" or under-the-table payment is tolerated. 

The company undertakes, in compliance with current legal provisions, not to establish any employment relationship with individuals lacking a residence permit and not to engage in any activities aimed at facilitating the illegal entry of clandestine individuals into the territory of the State. 

In particular, members are prohibited from engaging in any conduct aimed at the illegal entry of their family members, outside the hypothesis of family reunification, expressly regulated by art. 29 Legislative Decree 286/1998. 

Upon the establishment of the employment relationship, each employee, collaborator, and member receives accurate information regarding: 

1. the characteristics of the function and tasks to be performed; 
2. regulatory and remuneration elements, as regulated by the applicable employment contract for employees, as well as by federal regulations for the Company's Members; 
3. rules and procedures to be adopted to ensure that work is carried out in a safe and healthy environment. 

The contents of this Code of Ethics will be explicitly explained and made known at the time of hiring.

In personnel management, the Company undertakes, in any case, to: 

• offer equal job opportunities without discrimination based on race, gender, age, sexual orientation, physical or mental disabilities, nationality, religious belief, political affiliation, and union membership; 
• ensure fair and meritocratic treatment; ensure the protection of employees' privacy and their right to work without undue influence. 

The Company also commits to: 

• respect fundamental human rights; 
• prevent child exploitation.

The Company requires that in internal and external work relationships, no one is placed in a state of subjection through violence, threat, deceit, abuse of authority, exploitation of a situation of physical or mental inferiority, or a situation of necessity. The Company disapproves of any form of harassment, including sexual harassment. In particular, any behavior that may constitute psychological violence and/or psychological persecution aimed at offending the personality, dignity, and psycho-physical integrity of employees, as well as endangering their employment or degrading the work environment (bullying) is prohibited.

Protection of health and safety in the workplace

The company is committed to ensuring health and safety in the workplace in accordance with current legal provisions and in compliance with the obligations set forth in Legislative Decree no. 81/2008. A similar commitment is required from third parties where, for the performance of the Company's activities, it is necessary to use facilities or logistical support owned or managed by third parties. The Company works to promote a culture of workplace safety, developing awareness of risks and promoting responsible behavior by all employees and collaborators. It is the duty of every employee and collaborator to follow the instructions received and to respect preventive measures and safety procedures, avoiding adopting reckless or negligent behaviors that expose themselves or others to unnecessary risks or the danger of suffering harm to health or physical integrity.

Use of company assets

In order to protect company assets, every employee, collaborator, and Member is required to operate diligently, through responsible behaviors in line with the operational procedures established for their use, accurately documenting their use. Specifically, every employee, collaborator, and Member must: 1) use the entrusted assets scrupulously and sparingly; 2) avoid improper uses of company assets that could cause damage or reduce efficiency, or be contrary to the company's interests; 3) avoid improper uses of company assets for purposes unrelated to their duties and work. Every employee, collaborator, and Member is responsible for protecting the resources entrusted to them and has a duty to promptly inform their supervisor of any events harmful to the Company. 

The use of computer and telematic tools must comply with principles of correctness and be carried out in a manner that safeguards the confidentiality, integrity, and availability of the processed data, to protect the interests of the Company and third parties. In particular, it is expressly prohibited to:

• Illegally access a computer or telematic system;
• Fraudulently intercept, prevent, or interrupt, even by installing equipment, communications related to a computer or telematic system or between multiple systems, or disseminate the content of such communications to the public through any means of information;
• Destroy, damage, or render computer or telematic systems unusable, or programs, information, or data of the Company or others, or even endanger the integrity of those used by the State or another public entity or of public utility;
• Illegally possess, use, or communicate codes, passwords, or other means suitable for accessing a computer or telematic system; › Install and/or disseminate equipment, devices, or computer programs with the purpose or effect of damaging a computer or telematic system, or data or programs contained within it;
• Produce and/or transmit false and/or altered electronic documents or documents containing false and/or altered data

The Company adopts measures to ensure that access to telematic and computer systems and the data contained therein complies with current regulations and guarantees the confidentiality of information, ensuring that their processing is carried out by individuals expressly authorized for this purpose.. 

Prohibition on possession of pornographic material It is strictly prohibited to possess, on computer or paper media, within the premises of the Company, its warehouses, its related areas, or in any other location attributable to the Company, or to disclose through the Company's website or publications managed or promoted by the Company, pornographic material or virtual images created using images of minors under the age of eighteen. Virtual images refer to images created using graphic processing techniques not associated entirely or in part with real situations, whose quality of representation makes unreal situations appear real. 

Management of money, assets, or other valuables It is prohibited to purchase, receive, conceal, or in any way interfere with the purchase, receipt, or concealment of money or items derived from a crime. It is equally prohibited to transfer or replace money, assets, or other valuables derived from non-negligent crime or to carry out other operations related to them that hinder the identification of their criminal origin. Lastly, it is prohibited to use money, assets, or other valuables derived from crime in economic or financial activities.

To this end, all employees, managers, and collaborators are obliged to exercise the utmost attention and prudence, avoiding contact with assets or other valuables that, due to their nature or the particular conditions in which they are found or negotiated, may raise suspicion of having an illicit origin.

Associative crimes 

It is prohibited to associate in Italy or abroad for the purpose of committing one or more crimes of the same or different nature.

Counterfeiting of banknotes, coins, public credit cards, stamp values, and watermarked paper

It is prohibited to counterfeit, circulate, purchase, or sell banknotes, coins, public credit cards, stamp values, and watermarked paper for the benefit and/or advantage of the companies belonging to the Company. Anyone who receives counterfeit or stolen banknotes, coins, or public credit cards in the course of their activities as payment is obligated to inform their superior so that appropriate reports can be made.

Specific principles applicable to the youth sector

The objective of the Company is to develop a Youth Sector that combines the technical needs of the club with the education, growth, and pursuit of social maturity among young people. In particular, a primary value for the Company is the promotion of positive values in youth sports, recognizing that setting a good example for young people is the most immediate form of education in mutual respect. To this end, all employees, collaborators, players, and all individuals working in the youth sector are required to adhere to the general principles, obligations, and prohibitions mentioned above, as well as those specifically outlined here.  It is mandatory to constantly supervise minors entrusted to the Company, ensuring that they are not left unattended. Interactions with young people must be conducted impeccably in terms of moral correctness; no form of abuse towards young people, whether psychological or physical, will be tolerated. It is important to avoid being alone in closed spaces with a single child or young person. Guiding and educating young people should be done in accordance with models that promote ethical and human principles in general, and fair play in sports in particular. Maximum effort is required to preserve the psychological and physical health of young people, also to prevent deviations, doping, abuse, and commercial exploitation. Training and competitions should focus on developing motor skills, a safe and healthy competitive style, a positive self-concept, and good social relationships.

Penalties and controls Anyone who becomes aware of or has reasonable suspicion of violations or circumventions of the principles contained in this Code shall report it to whistleblowing@comowomen.it. 

The principles expressed in this Code of Ethics are an integral part of the conditions governing employment relationships within the Company: therefore, any violations of the Code will result in sanctions against employees, managers, Directors, and Auditors of the Company. Compliance with this Code is of essential importance for the Company; the violation of it, even by third parties linked to the Company through collaboration, consultancy, contract, service, or supply relationships, constitutes a serious breach and may lead to the termination of the same relationship.

From a control perspective, the Company ensures an internal work organization that guarantees: an adequate level of segregation of responsibilities, so that the implementation of each process requires the joint support of different company functions; all actions and operations of the Company have proper documentation and the decision-making, authorization, and execution processes can be verified; each operation is supported by adequate documentation to enable checks at any time to confirm the characteristics and motivations of the operation and identify the individuals who authorized, carried out, recorded, and verified the operation; all internal documentation is kept accurately, completely, and promptly in accordance with company procedures.

Entry into force, effectiveness, updating, and modifications 

The present Code of Ethics was adopted by resolution of the Company's Board of Directors in December 2024 with immediate effect. Any updates, modifications, or additions to this Code of Ethics must be approved by the Company's Board of Directors. A copy of this Code of Conduct and Code of Ethics is provided to all Recipients and is available for consultation in electronic format on the company shared drives, as well as in hard copy in the Company's training ground.