Foreword Vision Distribution is a Company belonging to the Comcast Corporation Group.

 Vision Distribution has decided to formalize a set of ethical and conduct principles within this Code of Ethics, to be spread both inside and outside the Company, when relating to third-party individuals. In particular, Vision Distribution deems that the adoption of a Code of Ethics, which clearly expresses in a transparent way the ethical and conduct principles on which the Company is based, is crucial to ensure its reliability and integrity – factors that contribute to the current and future success and development of the Company.

1. Guide to the Code of Ethics

1.1 Purposes, application and Recipients

The purpose of the Code of Ethics is describing the principles Vision Distribution believes in and through which it recognizes itself. The Code of Ethics is included in the system of rules to observe, and is an integral part of the Organization, Management and Control Model, adopter by the Company, pursuant to Leg. Decree 231/2001. The ethical and conduct principles contained in this Code are binding for all those actors playing a representative, administrative or managerial role in Vision Distribution, for all its employees, without exceptions, its partners and anyone else entertaining business relations with Vision Distribution (hereinafter, the “Recipient(s)”). The Recipients must know the contents of the Ethical Code, and are all asked to actively contribute to its enforcement. To this end, this Code of Ethics shall be suitably made know to all its Recipients.

1.2 Recipients’ Obligations

Every action, operation, transaction and, in general, any activity carried out by the Recipients must be done in full compliance of the provisions of this Code of Ethics. In particular, the Recipients must: comply scrupulously with the Code provisions, abstaining from any behaviour contrary to it; notify to your supervisor, or, where appropriate to the CEO, or through the existing confidential channel, even anonymously, any possible and/or alleged violation of the Code occurred within the Company; offer the utmost cooperation in ascertaining the possible and/or alleged violations of this Ethical Code. With regard to the reporting method for such possible and/or alleged violations of the Code of Ethics, the Company has implemented and made accessible, even in digital form, suitable tools and notification channels to ensure the reporter’s secrecy. The Company prohibits any direct or indirect retaliation or discrimination against the reporter; the same protection is ensured to any reported person.

1.3 Compliance and penalty provisions

 If any of Vision Distribution’s employees breach the provisions of the Code of Ethics, the Company shall implement – coherently, impartially and evenly – a penalty proportionate to the breach, and, in any case, in compliance with the law. Complying with the provisions of this Code of Ethics is an integral part of Vision Distribution employees’ contractual obligations, pursuant to and to the effect of Art. 2104 of the Civil Code and following. Breaching the provisions of the Code of Ethics may constitute an infringement of the obligations of the work relationship and/or a disciplinary offence, pursuant to the procedures set forth in Art. 7 of the Workers’ Statute, with all legal consequences, and may also affect the preservation of the work relationship and entail possible claims for damage. In addition, compliance with the principles of the Code of Ethics is an integral part of the contractual obligations accepted by our partners. If a third-party breaches the Code of Ethics, it may constitute an infringement of the obligations accepted by the same, with all legal consequences, including Vision Distribution’s right to terminate the contract and claims for damage.

1.4. Interpreting the Code of Ethics

 Vision Distribution, through the relevant corporate functions and its Supervisory Bodies: i. helps ensure the correct interpretation of the provisions contained in the Code of Ethics. To this end, for any clarification, the Recipients may refer to their supervisors, or to the HR Management or Legal Management; ii. assesses the actual compliance with the Code of Ethics; iii. is responsible for any future updates and implementations of the provisions of the Code of Ethics.

2. General ethical principles 

While carrying out its activities, Vision Distribution is inspired by the following general principles: Lawfulness, Equality and Impartiality, Professionalism and Transparency, Correctness, Reliability, Sustainability, Lawfulness when performing a job or professional service for Vision Distribution, the Recipients shall operate in full compliance with current law provisions and regulations.

Equality and Impartiality 

Vision Distribution promotes human rights and ensures compliance with the principles of equality and impartiality, by enhancing personal individuality, attitudes, skills and competences.


All of Vision Distribution’s activities must be carried out with the utmost commitment, diligence and professionalism, in a spirit of respect and mutual cooperation. The Recipients are asked to carry out their tasks with suitable efforts for the activities entrusted to the same, by preserving Vision Distribution’s image and reputation.

Transparency, Correctness and Reliability 

When carrying out the jobs and professional activities, the Recipients’ behaviour shall be inspired by the utmost transparency and correctness; the Recipient are compelled to provide reliable, truthful, accurate and complete information.


Vision Distribution regards confidentiality as the guiding principle behind every conduct. The Company ensures the confidentiality of the information disclosed to it, refrains from using confidential data – except where expressly authorized – and processes personal data in compliance with the Privacy Policy. The Recipients must refrain from using the Company or third-party’s proprietary and confidential information not in the public domain, of which they became aware on account of their role and/or profession, for personal purposes, and, in any case, for any purpose not related to the job or professional activity entrusted to them; the Recipients are responsible for protecting such information, and they can’t improperly take any direct or indirect advantage by exploiting confidential information. Such information may be disclosed to third parties only when duly authorized, and, in any case, in compliance with the corporate provisions. In most jurisdictions, it is forbidden to use privileged information to carry out operations on listed securities or financial instruments, as well as disclose such information to third parties or spread false news to affect the price of listed and unlisted financial instruments. Vision Distribution is aware that such conduct may affect also listed enterprises belonging to the Group, apart from any third party company doing business with the Company.


Vision Distribution spread a culture of acting responsibly, and works so that the Company’s success and growth do not prescind from the attention of their impact on the environment, the community and the people, in order to build a successful and long-lasting business. Vision Distribution asks the Recipients to comply with the principles of social and environmental sustainability contained in the Code of Ethics, when managing the jobs and professional activities.

3. Conduct principles in the relationships with people 

3.1 Value of a person and appreciation of human resources

Vision Distribution protects the value of a person against any form of discrimination and abuse related to gender, sexual orientation, age, race, language, religion, nationality, political and trade union opinion, disability and any other personal and social characteristic and condition. No form of discrimination against employees, partners or third parties shall be tolerated. Vision Distribution recognized the essential values of dignity of people and respect of diversity. Vision Distribution promotes the respect for human rights, by supporting inclusion and diversity in its activities and spheres of influence. The Company promotes the creation of a serene and collaborative work environment, characterized by proper behaviours, and fostering the valorization of the skills and competences of its employees, while respecting everyone’s personal individuality. Every person at Vision Distribution must help preserve an environment based on mutual respect, in compliance with the principles set forth in this Code of Ethics. Vision Distribution promotes a management of the relationships and hierarchical relations based on equity and correctness, and prohibits any behaviour that may be detrimental to personal dignity. Vision Distribution rejects any form of irregular employment, condemns child labour and any work conditions that entail the workers’ reduction to slavery. Recruitment and hiring are carried out while complying with the principle of transparency, by assessing the expertise, professional, skill and individual potential requirements. In order to enhance the skills and competences of its employees, Vision Distribution adopts criteria of merit and ensures equal opportunities.

3.2 Health and safety in the workplace

Within its activities, Vision Distribution pursues the objective of protecting the Recipients’ health and safety, by adopting all the relevant measures, pursuant to the law. To this end, Vision Distribution requires, at every corporate level, strict compliance with the health and safety provisions in the workplace, also to help create and preserve a safe, healthy and productive work environment. In particular, Vision Distribution’s health and safety management is based on the definition and implementation of general and specific prevention and protection measures, aimed at: minimizing risks, reducing accidents, injuries and occupational illnesses; improving the health and safety conditions in the workplace; preserving the health and psychological/physical well-being of Vision Distribution’s employees; training and providing suitable training on health and safety in the workplace.

3.3 Protection of the environment

Vision Distribution, being aware of the need to respect and protect the environment, strives to minimize the environmental impact of its products and services, promoting the diffusion of an environmentally-attentive culture. Vision Distribution is committed to give its contribution to protect the environment, raise awareness on safekeeping our Planet, and, in particular, promote virtuous behaviour and new organizational approaches with a lower environmental impact.

4. Conduct principles in the relationship with third parties In all business relationships (including those with customers, suppliers, Institution and business partners) Vision Distribution requires its Recipients to behave honestly, correctly and in compliance with the law and regulations.

4.1 Conflict of interest

While carrying out their activities, the Recipients must avoid situations with conflicting interests, where conflict of interest means when a Recipient pursues a different interest than Vision Distribution’s corporate mission, or carries out any activity that may interfere with its capacity of making decisions in Vision Distribution’s exclusive interest, or personally takes advantage of the Company’s business opportunities. In case of conflict of interest, without prejudice to the corporate policies applicable to specific Recipient categories, they shall promptly inform their supervisor, and accept the decisions taken on the matter.

4.2 Protection of competition

Vision Distribution, aware that free competition fosters an environment where enterprises are encouraged to work efficiently, to invest in research and development to create new value for consumers, thus increasing the choice and quality of goods and services offered on the market, observes the current regulations on competition, and refrains from implementing and/or promoting any unfair competition behaviour.

4.3 Anti-corruption

Vision Distribution refuses and condemns any form of corruption. Corruption means the direct or indirect offer, promise, payment, and acceptance of cash and/or other benefits or services in order to (i) prompt the recipient or any other person to act – while carrying out its activities – in a way contrary to its duties, or (ii) reward the recipient for having acted against its duties.

4.4. Relationships with Institutions, Public Administration and other Authorities

The relationships with the Institutions, Public Administration and other Authorities must always be inspired by the observance of the applicable law provisions, and the principles of transparency, honesty, correctness and cooperation, without compromising Vision Distribution’s integrity and name in any way. Only duly authorized corporate functions may undertake commitments and manage the relationships with Institutions and Public Authorities. When relating to Italian or foreign public third parties, the Recipients may not affect their decisions or judgement in an improper and/or illegal manner.

4.5 Relationship with suppliers, consultants and partners The Company’s relationships with third-party suppliers, consultants and partners are based on the principles of mutual integrity, professionalism, correctness and transparency. Any behaviour incompatible with this Code of Ethics may be construed as a serious breach of the contract, grounds for damaging the relationship of trust, and just cause for terminating the contract.

4.6 Correctness and transparency of corporate information

Every action, operation and transaction must be suitably documented and accounted for in a correct, accurate, complete and prompt way, in compliance with the law and with the applicable accounting principles. The decision-making, authorization and implementation process for any operation, as well as the identification of different levels of liability, must always be verifiable

5. Other specific principles of conduct 

5.1 Intellectual property

All Recipients must operate in compliance with the laws on intellectual and industrial property. To this end, Vision Distribution acknowledges, respects and protects any form of intellectual and industrial property, and condemns any possible fraud, illegal duplication or reproduction, counterfeiting, fraud or alteration of any material or immaterial assets susceptible to ownership rights resulting from own or third-party industrial or intellectual property rights. Intellectual and/or industrial property rights on assets conducive to protection, created, developed or realized within the work activities, belong to the Company, which detains the right to use them in the ways and forms deemed more appropriate, without prejudice to the moral right of their authors to be recognized as such. The Recipients must refrain from: use or spread a protected original work or part of it to the public, without being so entitled, for any purpose or in any way; use equipment, products or components or provide services aimed at eluding the technological measures that protect the original works; use company secrets of others; illegally reproduce, mimic, or tamper with third-party trademarks, distinctive traits, patents, industrial drawings or models; using trademarks, distinctive traits, patents, industrial drawings or models counterfeited by third parties for industrial and/or commercial purposes.