1. Introduction

2. Our responsibility

2.1 Professional practices

2.2 Conflicts of interests

2.3 Confidentiality

2.4 Data Protection

3. Our commitment

3.1 Equal opportunities

3.2 Harassment and Bullying

3.3 Workplace and personal safety

3.4 Whistleblowing

4. Clients and third-party relationships

4.1 Suppliers and contractors

4.2 Gifts and entertainment

5. Compliance with legal standards

5.1 Anti-bribery and anti-corruption

5.2 Senovo IT Policies

5.3 Compliance with this Code

1. Introduction

Senovo's story goes back to 2013, when a passionate entrepreneur left his high-flying job as a Director of one of the UK's top recruitment agencies. He stepped out of his comfort zone to achieve his life dream of founding the most exciting, disruptive, forward-thinking, and fun IT recruitment company ever.

This would have not been possible without the immense and loyal help of a strong, dedicated, and passionate team, the Senovo IT family.

As a global company, we continue to diversify our offering, appealing to a wider and more inclusive range of talent. We support inclusive disruption, working with diverse innovators, creators, and leaders within the Tech world. Our aim is to mentor the rising tech talent of the future today, hence the idea of launching Senovo IT Education materialised, our IT training platform.

Fast forward 8 years, Senovo IT has become a key player in the IT digital universe, partnering with top clients globally

Senovo IT Group including Senovo IT Ltd (London) and Senovo IT S.L. (Barcelona), (“Senovo”, “we”, “us, “our”) is a leading Information Technologies consulting service provider. It was founded in 2013 by Fabrizio Innamorati and is currently present in 15 countries bringing talent, drive and innovation to national and international projects. We provide business solutions and assistance to Information Technologies professionals in finding suitable assignments on their skills and their level of expertise.

This Code of Conduct (the “Code”) stipulates the standards of behaviours and professional practices that applies to all of us.  Senovo requires the highest standards of professional and ethical behaviour from its employees, consultants, contractors and directors.

Our core values are:

  • Honesty
  • Commitment
  • Professionalism
  • Transparency
  • Integrity

All of us can face challenging situations in a fast-changing business environment and this Code is intended to provide guidance on own values, standard and policies.

The non-compliance with the Code could result in breaching laws and regulations. If you have any question or concerns about the content of this Code, please contact legal@senovo-it.com for advice. 

2. Our responsibility

2.1 Professional practices

We strongly believe that a professional behaviour is fundamental in order to achieve success in business and to build strong relationships based on trust and loyalty with clients. Senovo is willing to continue growing and evolving as a business in an honest and competent manner while taking into consideration all the core values.

We intend to strengthen trust and confidence with our candidates and clients through providing services in an outstanding ethical and professional manner.

Consequently, us at Senovo are accountable to behave with transparency and integrity when performing our duties and tasks.  We encourage everyone to take proactive measures and to ensure compliance with principles of the present Code, which is a crucial tool for our organisation.

At Senovo, we commit to comply with the applicable laws, regulations, internal policies, processes and to promote equal opportunity, diversity, and equality.

Therefore, implementing the said Code should be seen as a collective effort. Furthermore, many of us have leadership roles and we need to ensure the compliance and application of this Code into our daily work. Management shall uphold exemplary standards of conduct and create a positive working environment encouraging individuals to speak up and to seek for advice. We are enabling the staff to raise professional and ethical matters without fears of retaliation by supporting them in making ethical decisions and in compliance with the Code’s guidance.

All employees, consultants and contractors representing  Senovo, as well as directors, shall adhere to this Code. Failure to comply with this Code, Senovo’s policies or laws and regulations may result in a disciplinary action, which can result to a dismissal or termination of an assignment, as well a potential civil and/or criminal liability. 

2.2 Conflicts of interest

Conflicts of interests can appear in the work environment and take many forms. They arise when an individual has two or more competing interests and when serving one of those could damage or harm the other interest and could undermine trust and cause reputational damage. Even if an interest has not developed into an actual conflict, just the perception that there is a conflict can impact the company’s reputation.

Conflicts of interest can take several forms because of the difference in the nature of relationships or interests and fall into two main areas:

  • Financial
  • Personal
  • Maintain the highest possible standard of integrity in all business relationships inside and outside the organisation.
  • Reject any business practice which might reasonably be deemed improper, including all improper practices which might benefit Senovo.
  • Never use authority or position for personal gain.
  • Act with impartiality and independence at all times.
  • Avoid being in a position which might result in a perceived or actual detriment to Senovo’s reputation and interest.

Where an individual has a financial interest outside the company, actions which could damage the company may provide the individual with a direct or indirect personal gain.

These conflicts are rooted in personal relationships. We must avoid favouring any candidate’s application because of a personal relationship and we must not be involved in any placement with whom we have a familial, romantic, or even friendship relationship.

We shall avoid situations that could create conflicts of interests and we should take special care to ensure that our personal interests do not conflict with Senovo’s responsibilities and interests. It is our responsibility to prevent these situations by ensuring that our business decisions and relationships are not based on personal interests.

We are expected to:

Moreover, transparency is crucial when dealing with both actual or perceived conflicts. Consequently, this is the reason why we should all disclose any such interest or relationship that could interfere with the company’s interest when competing interests harm our ability to make objective and unbiased business choices.

Please bear in mind that everyone could come across a conflict of interest, this being acceptable as long as we are transparent and contribute to its mitigation.

If you are in doubt as to whether a conflict of interest exists, you should notify the relevant manager in the organisation and seek direction and guidance on the issue which may potentially conflict with your responsibilities at Senovo.

Senovo will evaluate the situation and if needed will take all reasonable steps and measures in order to avoid a conflict and will remove the person concerned from the decision-making process. 

2.3 Confidentiality

The nature of our services gives us access to information that should be not disclosed to others, therefore we are committed to ensure the security, privacy and confidentiality of all information that has been shared with us.

Moreover, we keep certain types of information confidential for legitimate interests, including complying with legal standards and maintaining a competitive edge over competitors.

Maintaining confidentiality requires staff’s commitment and cooperation. We must do the following in order to ensure the confidentiality of some type of information:

  • Not access or use any confidential information to which the staff has not been provided access or authorised to use.
  • Not disclose, publish, communicate, or make available confidential information to anyone that does not have the authority to know and use this information.
  • Not share confidential information with a third-party unless Senovo and the third-party enter into a confidentiality agreement.
  • Ensure that all confidential information is stored in a secured location with limited access and not removed from our premises unless it is specifically approved in writing by the staff’s manager in order to perform the job duties
  • Not discuss confidential information in public where it may be overheard.

In the event of a disclosure, the staff should immediately inform the corresponding manager and Senovo’s Legal Department so that appropriate measures can be taken to minimise damage. If  the staff is unsure whether information should be kept confidential, the manager can provide advice before disclosing the information or taking any other action.

2.4 Data Protection

We respect data subjects’ privacy at all times and we are strongly committed to protect our data and the data of our clients, third parties and candidates, as well as personal data and information about our staff. We are processing data with all due skills, care and diligence in a lawful, fair and legitimate manner in accordance with all applicable procedures, laws and regulations.

Detailed information about how we collect, and process personal data can be found in https://www.senovo-it.com/priv....

3. Our commitment

3.1 Equal opportunities

Senovo is committed to equality and to promote a fair work culture, free from discrimination, internally and externally. We are responsible for encouraging and promoting an inclusive and diverse work culture.

All candidates, clients, employees and business partners will be treated with dignity and respect and will receive equal treatment regardless of age, disability, gender, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation.

We take a proactive stance against any type of discrimination, and it will not be tolerated in our organisation. If you believe an individual has suffered discrimination in connection with our organisation you can raise the matter to Senovo’s management or Senovo’s Legal Department. All complaints will be treated in confidence and investigated as appropriate, and you will not be victimised or retaliated against for complaining about it.

3.2 Harassment and bullying

We believe in a work environment free from harassment, bullying and intimidation.

Harassment is any unwanted physical, verbal or nonverbal conduct that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. It also includes treating someone less favourably because they have submitted or refused to submit to such behaviour in the past.

Unlawful harassment might involve conduct of a sexual nature, or it might be related to age disability, gender, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation. It will not be tolerated even if it does not fall within any of these categories.

Bullying is offensive, intimidating, malicious or insulting behaviour involving the misuse of power that can make a person feel vulnerable, upset, humiliated, undermined or threatened. Power does not always mean being in a position of authority, but can include both personal strength and the power to coerce through fear or intimidation. It can take the form of physical, verbal and non-verbal conduct.

If someone in connection with our organisation is being harassed or bullied, speak to Senovo’s management or Senovo’s Legal Department who can provide advice and assistance in resolving the issue in a discreet and confidential manner. We will investigate any complaint of harassment o bullying and we will do all that is reasonably possible to eradicate such behaviour.

Senovo has zero tolerance for this type of conduct, which may result in a disciplinary action, up to dismissal or termination of an assignment.

3.3 Workplace and personal safety

Our aim is excellence in health and safety and we take appropriate health measures to protect the security of the staff and anyone visiting our premises or affected by our work. We will do our best to mitigate the incidence of risks in the workplace.

All of us share responsibility for achieving safe working conditions. All individuals should take reasonable care of their own health and safety, as well as ensuring other people’s health and safety who may be affected by their behaviour and observe applicable rules and instructions in the workplace.

The staff should report any health and safety concern immediately to Senovo’s management and Senovo’s Legal Department and cooperate accordingly.  

3.4 Whistleblowing

We are committed to conducting our business with honesty and integrity and we do not tolerate any wrongdoing that could lead to non-compliance with this Code. Any suspected misconduct should be reported as soon as possible with the relevant manager or, when the staff prefer not to raise it with Senovo’s management for any reason, any unethical conduct should be reported to Senovo’s Legal department.

We encourage openness and we will support whistle-blowers who raise genuine concerns under this Code, even if they turn out to be mistaken. They must not suffer any detrimental treatment as a result of speaking up and we will reassure all their concerns will be taken seriously and will be investigated accordingly.

We will make every effort to preserve the privacy of your identity and only share it when necessary for legal reasons. 

4. Clients and third-party relationships

4.1 Suppliers and contractors

We are committed to ensure that we only engage competent suppliers and contractors that comply with our quality standards. We engage with them considering their own merit and competence to undertake the assignment to carry out the services to the highest standards as per our preferred supplier list.

We expect all our actual and prospective suppliers and contractors to take into consideration the standards outlined in this Code and to promote it in their own supply chain. All contractors and suppliers shall be aware of and, as far as reasonably practicable, comply with this Code and Senovo’s policies.

4.2 Gift and entertainment

Giving or accepting a gift or hospitality access for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services is not expressively prohibited provided that it does not impact our decision making. Nevertheless, accepting or giving a gift, favours, or hospitality access would not be appropriate if it could lead to an inducement or reward for achieving any preferential treatment.

We should consider the value, the reason and the type of gift to assess the appropriateness of it. It is strictly prohibited to accept any gift that includes cash or cash equivalents or that is given in secret. Please bear in mind that gifts must be given in the our organisation’s name.


5. Compliance with legal standards

5.1 Anti-bribery and anti-corruption

Senovo IT is committed to a zero-tolerance approach to bribery and corruption. We conduct all business in a professionally and ethical manner and we expect all the staff, clients, suppliers, contractors or any third-party to whom we deal to not enter into corrupt practices.

All forms of bribery such as offering, promising, giving, accepting, or seeking a bribe to secure a business or to gain any type of advantage are strictly prohibited.

We expressively prohibit the following:

  • Give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
  • Accept any offer from a third-party or client that is made the expectation that we will provide a business advantage;
  • Give or offer any payment to a government official in any country to facilitate or speed up a procedure.

The detection and prevention of bribery and corruption are the responsibility of all of us. Therefore, we must avoid any type of corrupted practices that might lead to a breach of this Code and we must take appropriate action where we suspect any type of misconduct.  Please do notify Senovo’s Legal Department as soon as you suspect any wrongful conduct that has occurred or might occur in the future.

Please remember that any failure to comply with this section can lead to a disciplinary action, which could result in dismissal for gross misconduct or in the termination of the assignment with immediate effect.

5.2 Senovo IT Policies

This Code will be amended from time to time together with all implemented policies and guidelines. We encourage you to periodically review this Code and Senovo’s policies in order to be familiar with the latest versions of them.

All staff, clients, suppliers, consultants and third parties with whom we deal with shall be subject to this Code and Senovo’s policies, procedures and directives.


5.3 Compliance with this Code

This Code provides the primary standards of ethics and professional practices based on Senovo’s values. It reflects all shared commitments and responsibilities that we expect from the staff, consultants, clients, suppliers and any third parties with whom we have a business relationship with.

If you need assistance regarding the implementation of this Code or you would like to report any wrongful misconduct, please raise your concerns and questions with Senovo’s management or Senovo’s Legal department. All concerns will be heard and will be managed with all due respect and confidentiality. We will take appropriate action where necessary.

Any suggestions and comments are welcome as we are committed to improve and adapt this Code to our ethical principles.