TECMA philosophy

1. INTRODUCTION
The real estate sector is a complex, dynamic and ever-changing one. In order to face the market challenges it is necessary not only to have an insight of the dynamics of the real estate sector but it is also essential to keep up with the sociological and technological trends which galvanize change on a local and global scale. For some years now, while keeping the typical characteristics of artisan production, the development of a real estate project has required careful and punctual planning of the commercial, marketing and communication strategies just as for any other industrialized sector. And TECMA SOLUTIONS S.p.A. fits in right here. TECMA, founded in 2012, is specialized in technical marketing, business strategies and real estate development  supporting companies, developers and investors operating in Real Estate.

With the aim of exploring new market opportunities, TECMA adopts a truly original approach destined to revolutionize the very concept of business in the world of Real Estate. Between 2012 and 2016 the company consolidated its leadership in the Milan market, going on to saturate it; 2016 marked a new chapter aimed at laying the foundations for targeting the stock market. The constant focus on new technologies, on Research and Development has led to the development of innovative patented techniques which seamlessly blend together art and science: one of these is More Than Virtual® technology, a crowning achievement in architectural visualization. Moreover, all TECMA SOLUTIONS S.p.A. products and services are developed on the basis of continuous research and studies on the behaviour of the final consumer/client.

Neuromarketing and more generally speaking neurosciences offer the opportunity to draw valuable stimuli able to remarkably contribute  to a better understanding of the mind and theneeds of consumers. In February 2018 TECMA SOLUTIONS S.p.A. reached an important milestone by becoming a S.p.A (a Joint-Stock Company): a new corporate structure synonymous with a profound structural change aimed at initiating anew path. Thanks to its in-depth market know-how and expertise, its overall strategic vision and its strong spirit of observation the company recorded its first capital increase and a reorganization was put into place:  taking it from being a Consulting Company to an Investment Company.

TECMA SOLUTIONS S.p.A. (hereafter ‘TECMA’) does not develop operations on its own, instead it invests micro-equity in real estate operations by participating as a partner and financing the complex go-to-market phases. It participates with its own investments in defining winning commercial strategies, producing all the necessary tools to support real estate development in-house and its ROI is based on the success of the operation.

The business model means that, thanks to the multidisciplinary skills of its fifty professional staff, the company is able to avoid any form of outsourcing, controlling all commercial launch processes and offering extensive know-how ande xpertise. With approximately two hundred projects located in more than fourteen Italian regions, TECMA has begun to tap into new markets, an expansion that sees the company strategically positioned in three continents: North America, Central Europe and the Middle East. TECMA, with a strategic business plan aimed at consolidation and growth in Milan, Rome, Monaco, Zurich, London, New York and Dubai, aims to become the undisputed worldwide leader of  Real Estate Marketing Technology. In the future Los Angeles, Miami and the Far East will also be part of the roadmap. The focus will stay on research and development with targeted and planned investments in every strategic business plan, favoring long-term growth over short-term speculative actions aimed at increasing profits for investors. TECMA is innovative technology and collaborative dynamism: a multidisciplinary company with professional know-how and expertise forged over time, the result of continuous research and a real drive for innovation.

TECMA has managed to anticipate the trends in its sector, addressing its growing complexity and responding to the ever-more diversified needs of its operators and the final consumer. It has been able to  successfully identify and emphasize one of the key, essential factors in Real Estate: to always put people at the center and  have a human centered approach. The growth strategy aims to create solid and sustainable values from an economic, financial, social and environmental point of view based on the following values:

INTEGRITY: We pursue our objectives with honesty, fairness and commitment, in full compliance with regulations, professional ethics and in the spirit of the agreements signed.

EXCELLENCE: We set ourselves the goal of continuous improvement, looking ahead, anticipating challenges, nurturing creativity aimed at innovation and enhancing value.

VALUE OF PEOPLE: Value of people as such guides our actions, we adopt listening and dialogue strategies as stimuli for continuous improvement in all professional relations.


1.1 TECMA’S CODE OF ETHICS
The Code of Ethics defines the general principles in the management of TECMA’s activities, as well as the obligations and responsibilities in relation to employees and in general to all those who, directly or indirectly, permanently or temporarily, establish and build relations or who act for and on behalf of TECMA. The Code of Ethics should be intended as a guideline in the daily actions of all and is the basis of the relationship of trust that binds TECMA to its employees and in general to all those with whom it has relations.  1.2 The Use of the Code of Ethics The Code of Ethics is formally approved by TECMA’s Board of Directors. It should be underlined that in the event that the laws and regulations in a country involved in the operations of TECMA are more permissive than those set down in the Code of Ethics, those of the Code of Ethics must be adopted. 1.3 Interpretation and Infringement For any issues related to the Code of Ethics, employees and third parties are invited to contact the corporate office. Any infringement or alleged violation must be notified to the Board of Directors and the Board of  Auditors.  

2.GENERAL POLICY GUIDELINES
TECMA fosters every single action on the following  principles: legality, honesty, fairness, integrity, transparency and mutual respect. Integrity & legality We operate with respect for the individual as well as for the community, we communicate transparently, honestly and fairly; We conduct our business in full compliance with the laws and regulations of the countries in which we operate. Respect, responsibility & commitment  We treat others with integrity and respect, we behave responsibly within the communities and environments in which we live and work, We are responsible for using there sources assigned to us and for recognizing a fair financial return for our shareholders; We firmly believe that the growth and professional advancement of our employees is the key to company success  2.1 CONFLICT OF INTEREST Any decision or choice made on behalf of TECMA must reflect TECMA’s best interests. Any in-house activity, investment, business strategy, participation in real estate or other transactions will be undertaken with the aim of generating an advantage for all the stakeholders and categorically excludes any form of conflict of interest with one or more investors. Employees at all levels and all other subjects bound by the Code of Ethics must avoid any situation which can, in any way, compromise the impartiality of their judgement regarding liability towards TECMA, other employees, customers or suppliers. Any employee, partner or collaborator who deems to be in a situation of potential conflict of interest must promptly report it to their Management. By way of example, conflict of interest may arise when an employee, a partner or a member of their family has a financial interest that may affect his or her judgement; when an employee, a partner or a member of their family gains profits through the access of confidential information; when an employee, partner or a member of their family has a personal interest, be it direct or indirect, in any supplier or client; when an employee, partner or member of their family has established a business activity on a stable basis, or any relationship of a financial, commercial, professional, family or friendly nature with a company other than TECMA, such as to affect the impartiality of their professional conduct. In addition to those hypotheses provided for by law, conflict of interest also arises when a subject acts to fulfil an interest other than that of TECMA. 2.2 OBLIGATION OF CONFIDENTIALITY The company honours a relationship of mutual trust and loyalty with its employees. The obligation of loyalty means that it is forbidden to carry out any activity that may be contrary to the interests of the Company or somehow incompatible with one’s own office duties. All employees must consider their compliance with the Code of Ethics as an essential part of the obligations undertaken within the professional relationship of trust and loyalty. Confidential information, related to data or knowledge belonging to the Company must not be obtained, used or communicated except by those authorized persons: “price sensitive” information is particularly important confidential information. Price sensitive information is information regarding facts that are not in the public domain, and if made public, may influence the price of financial instruments. Such information must in no way be used to take advantage of any kind, be it direct or indirect, immediate or future, personal or patrimonial. 2.3 CORRUPTION, ILLEGAL PAYMENTS AND MONEY LAUNDERING PREVENTION TECMA, all its employees and those bound by the Code of Ethics undertake to act with ethical integrity, honesty and fairness in all relations within and outside TECMA. No employee may accept, solicit, offer or pay any monetary amount or other expediency either directly or indirectly. Any form of pressure towards public officials or to any party in any way connected to public officials, in any form or manner, in any jurisdiction, regardless of local business practices, is prohibited. TECMA employees are forbidden to offer gifts, presents or other benefits that may constitute violations of laws and regulations, or are contrary to the Code or may be detrimental to TECMA, even if only in terms of image. TECMA and its employees, will take the necessary steps to check in advance any information on their commercial counterparts and suppliers in order to ascertain their reputation and the validity of their activities before entering into business with them.

3. THE BOARD AND EMPLOYEES
The Code must be considered an essential part of every assignment and engagement at Board level and of the employment contract of every employee. Both the Board and employees are required to comply fully with the specified provisions. In particular they must: adapt their behaviour to the provisions of the Code; refrain from any conduct that may damage the image of TECMA; promtly report any violations of the Code and cooperate in any related investigations, comply with all the in-house procedures as set out by TECMA. 3.1 Work Environment and Equal Opportunities Employees at all levels must adopt a professional conduct that guarantees a respectable work environment, a place where free domand dignity is respected. In particular: they must avoid conduct that may create an intimidating or offensive atmosphere; they must avoid behaviour aimed at discrediting colleagues and/or subordinates, they must not work under the influence of alcohol or drugs, they must comply with the ban of smoking in the workplace. With regard to Human Resources, the criteria principles behind all company roles, new hirings and work interruptions or stoppages will be, without any exception, meritocratic and strategic and not political. TECMA acknowledges equal opportunities for all employees from an economic and professional point of view regardless of race, class, origin, religion, disability, gender, sexual orientation, union membership or political affiliation or marital status. 3.2 Harassment Any form of physical or verbal harassment aimed at harming the dignity of the individual, both inside and outside the workplace, is strictly forbidden. Every employee, collaborator and individual bound by the Code who is in possession of information highlighting a situation of harassment is required to promptly report it to the Board of Directors and the Board of Auditors. 3.3 Company property All individuals are responsible for the safekeeping and conservation of assets and resources, both tangible and intangible, entrusted to them to carry out their work. The resources must be used solely for the purpose of office operations and in compliance with TECMA procedures. 

4. CLIENTS AND SUPPLIERS
In relations with third parties, every relationship must be managed without turning to any form of illegal behaviour; every action must be in full compliance with the law and the ethical values as expressed herein. Any practices of corruption, collusive behaviour, personal favours aimed at creating advantages for oneself or for others are expressly prohibited. 4.1 Clients TECMA acknowledges the strategic importance of its clients and requests that their management is carried out on the basis of the principles of honesty, fairness, professionalism and transparency. In its negotiations with customers, TECMA must not adopt any discriminatory behaviour or make any improper use of their bargaining power. 4.2 Suppliers TECMA acknowledges the strategic importance of Partnerships with its suppliers and therefore requests that their management is based on the principles of honesty, fairness, professionalism and transparency. In its negotiations with suppliers TECMA companies must not adopt any discriminatory behaviour or make improper use of their bargaining power or exert pressure of any kind so that unlawful behaviour is adopted by suppliers. The selection of suppliers and the definition of purchase conditions must be carried out on the basis of an objective evaluation, taking into account not only the price but also, and above all the suppliers’ honesty, integrity and ability to guarantee services at a fitting level. 

5. EXTERNAL RELATIONS
TECMA and its employees are fully committed to developing and endorsing socially responsible behaviour. 5.1 Public Organizations and Institutions Taking on commitments with the Public Administration and with Institutions is exclusively reserved to those authorized and designated company roles. They must not, under any circumstance, promise or offer Public Officials or employees of the Public Adminstration or Institutions payments or goods of any kind to promote or favour the interests of the Company. 5.2 Trade Unions and Political Parties Any relationship undertaken between TECMA and trade unions, political parties and their representatives must be based on the upmost transparency and fairness. Economic contributions are allowed only if permitted by law and in any case must be expressly authorized by the corporate authorities. 5.3 Communication, corporate information and media relations, Media communication plays a key role in creating the image of TECMA and therefore all information regarding TECMA must be provided in a true and uniform manner and only by senior management and the external relations manager. All the other employees must refrain from disclosing non-public information to the media.

6. ENVIRONMENTAL HEALTH AND SAFETY COMPLIANCE
The Group undertakes to protect the health and safety of all its employees in compliance with the law in force. Every employee must take the necessary steps to ensure that they do not put others in front of unnecessary risks that cause damage to their health or physical well-being.  

7.  IN-HOUSE CONTROL SYSTEM
‍It is the responsibilityof those more senior management members of the company to endorse the importance of control procedures in order to reach the company’s objectives, while the responsibility of fostering an effective in-house control system belongs to every staff level. All employees and all those who, directly or indirectly, permanently or temporarily, have relationships or act for and on behalf of the company are responsible for implementing the necessary controls in line with company procedures. Whoever becomes aware of  any omissions, falsifications or negligence is required to report the facts to the Board of Directors and the Board of Auditors.