Social Media Policy

Social media, more specifically platforms for socialization, are means of communication, sharing, exchange of opinions and interests, for the creation of contact networks as well as for the diffusion of content and information.
The use of social media in allowing the diffusion of content anywhere in the world increases the responsibilities of those who use them precisely because such content is intended for an indeterminate mass of subjects.
Drafinsub s.r.l. in addition to publishing institutional content on the website www.drafinsub.com, it is also present on some social network (specifically: Twitter, Facebook, Linkedin, YouTube and Instagram), according to institutional and general interest purposes, to promote its business and to inform in real time of initiatives and offered services. The Company, although recognizes the value of social media, believes that the protection of its reputation is nevertheless of fundamental importance.
The Social Media Policy (SPM) is the code of conduct, formally adopted, which provides the main rules of conduct that all employees, whether temporary, permanent, maritime or land, collaborators, as well as suppliers, customers, visitors and in any case all subjects who have relations with Drafinsub srl, are required to observe whenever they publish, share or comment on contents concerning the Company, regardless of whether the interaction on social networks is carried out through an official Drafinsub account or that takes place through a personal account of the User.
Incorrect use of social channels, in fact, can:

• damage, even seriously, the image and reputation of Drafinsub s.r.l. and, consequently, of the professional figures who work there;
• expose to direct damage (e.g. claims for compensation), in the event that content infringing on copyright and intellectual property is published.

This policy outlines the principles to be observed, the methods allowed for carrying out activities on the internet concerning the Company and the actions to be taken in case of violation.
All the official social profiles of Drafinsub s.r.l., are administered and managed by the Social Media Manager who has the task of monitoring the reputation of Drafinsub s.r.l. and its representatives on social networks, evaluating posts and conversations in which the Company is mentioned through tags (@drafinsub) and hashtag (#drafinsub).
Persons in charge of preparing creative content on behalf of the Company must be aware that, at the time of publication, they are speaking on behalf of the Company and to a particular audience and must always ensure that the shared content:

1. are unassailable: the Internet does not forget and any content can be “brought to light” and used against the author or against Drafinsub s.r.l. at any time;
2. do not disclose: personal data; corporate material protected by intellectual property rights (including copyright); confidential information.

The textual, photographic and video contents promoted on the social channels of Drafinsub s.r.l., at the time of publication, must always meet the following requirements:

1. they must be positive and in no way aimed at comparative advertising;
2. they must comply with company policies and be in line with the values expressed in the Code of Ethics;
3. they must refer to topics, events, products of interest to the Stakeholders; (iv) must provide information that is certain, verified and that always respects the copyright of others.

Data shared by users through private messages sent directly to the channel managers will be processed in compliance with the European Regulation EU 2016/679 and what is reported in the privacy policy.

External Social Media Policy

The external social media policy contains information addressed to users about the purposes, types of content and behaviors allowed on the institutional pages / profiles created by the Company.

Drafinsub recognizes and protects everyone’s right to the free expression of their thoughts; in order to guarantee freedom of expression without infringing the rights of others.

Drafinsub adopts an external social media policy, which illustrates to users the rules of conduct to be kept in the areas where the Company is located and indicates which contents and relationship methods should be expected from the same and defines:

• the type of content that will be published;
• the information pursuant to the legislation on the confidentiality of personal data (so-called “privacy policy”);
• the permitted behaviors;
• the contacts to which users can contact (for example to report abuse or copyright infringement).

The social channels produce their own textual content, photographs, infographics, videos and other multimedia materials that are to be considered under license, can be reproduced freely, but must always be credited to the original reference channel. It is therefore preferable to use the social functions (SHARE, RT, ..) to share the contents of the Company. Otherwise, in the case of republication as proprietary content, it is necessary not only to indicate the source (Drafinsub s.r.l.), but to mention it through the relative social functionality.

We remind you that the processing of personal data of users of social media by Drafinsub s.r.l. responds to the policies in use on the platforms used (Instagram, Facebook, Youtube, Linkedin and Twitter).

MEMORANDUM

For any matter concerning the contents involving the Company, it is possible to contact the Company by telephone at no. 010 261354 and / or by e-mail at the following address: [email protected].

Internal Social Media Policy

The internal social media policy identifies the main rules of conduct that all company personnel are required to observe when accessing social media with their personal accounts. The objective of this policy is, in fact, to avoid situations that do not comply with corporate ethical principles or that may, even potentially, harm the Company and consequently all the staff who collaborate with it.
The image of Drafinsub s.r.l. on social media it is the responsibility of all staff with the consequence that, therefore, each:

1. in the configuration, use and management of his private accounts on social networks, he is required to comply with the rules of conduct, aimed at safeguarding the interests of the Company and of the people who work there, in accordance with the provisions of the employment relationship as well as the current code of Conduct;
2. in sharing the contents – such as information on initiatives, projects, campaigns, videos and / or images – disseminated by the (official) social channels of Drafinsub Srl on their private profiles, they are required to comply with the Company’s communication strategy, designed to to ensure the dissemination of updated information on the activities performed, through all the communication channels at its disposal which must always be synchronized and therefore consistent in content and style with the other communication channels of the Company.

Some attitudes, in fact, could be punishable under the corporate disciplinary code and the sector national collective bargaining agreement.

In common interpersonal behavior, which extends to all forms of communication, including the use of social networks is, therefore, necessary:

• Be responsible.
  1. Pay particular attention to the sharing of material, especially with reference to the services performed for the Company also in favor of third parties, sharing only the contents, photographs or videos of company assets or customers of the company, in particular boats, structures or people , which are published directly by Drafinsub srl on their official social media.
  2. Interfacing, in the event that you intend to publish content from scratch concerning Drafinsub s.r.l., regardless of the social media used, with the Company’s Social Media Manager, before publication, in order to avoid the dissemination of sensitive information without the authorization of the Marketing Service.
  3. Avoid the dissemination on your private profile of content or information regarding Drafinsub s.r.l. not previously reported on the official social channels and / or not disclosed on the Drafinsub s.r.l. website or on another institutional reference site.
  4. Report any comment you become aware of, concerning the Company, which you believe may, even if only potentially, be harmful to its reputation or you are in doubt or are not sure how to reply to a post, it is necessary that such circumstances are communicated to their manager and / or to the Management.
• Be respectful. Always respect others in any social interaction.

WHAT TO DO

• Respect the ethical principles of Drafinsub S.r.l.
• Keep in mind that the photos or opinions relating to the business or exercise of the Company concern the latter and must be addressed only to the same.
• When expressing opinions regarding employment issues, clearly indicate that the ideas / opinions expressed are yours. This is why it is always necessary to speak in the first person.
• Respect the rules on copyright, intellectual and industrial property, copyright, trademarks and those relating to privacy.
• Formulate any intervention with the utmost respect for others: the company, colleagues and their privacy, users, stakeholders in general, etc., avoiding references to the work they are carrying out or in general to the activities carried out as part of the activity company, without prejudice to information in the public domain and / or published directly by Drafinsub Srl on their social networks.
• If you are contacted by any user about an official company content shared by this on social networks, you are asked not to engage in a dialogue directly and to report it directly to your manager and / or to the Management.

WHAT NOT TO DO

All personnel are required, by way of non-exhaustive example, to:

• not to disclose information internal to the company and / or in any case inherent to the activity carried out and / or in any case confidential, such as internal correspondence, information from third parties (private individuals, other employees, customers, contractors, suppliers, competitors or other Public Administrations, etc.) learned in the workplace, or information on work activities, services, projects and documents not yet made public, decisions to be taken and measures relating to proceedings and / or activities and / or work in progress and / or in any case connected to the Company and not made public;
• not to disclose, with the exception of public events, which take place at the workplace or even outside the same, photos, videos, or other multimedia material, without the explicit authorization of the company, facilities and people involved;
• do not act as a spokesperson in the event of negative posts or comments on the company and report such posts to the Management;
• do not misuse the brand and company name. Do not use the logo owned by Drafinsub s.r.l. on personal accounts, without the prior authorization of the Social Media Manager and / or the Management and in the manner established by the Company.
• not to use social media or similar forms of communication to attack or insult the company, colleagues, customers, contractors, suppliers, competitors or others;
• refrain from commenting on legal matters relating to the company, companies, financial results, competitors, strategy or rumors;
• do not create posts or comments that could be considered obscene, threatening, harassing or embarrassing to others;
• do not open blogs, pages or other channels in the name of Drafinsub s.r.l. or that deal with topics related to its activity, without the prior authorization of the Social Media Manager and / or the Management.

Without prejudice to the hypotheses in which violations of the aforementioned rules of conduct are a source of criminal, civil, administrative or accounting liability of the author, any conduct that may even potentially damage Drafinsub s.r.l. in any form will be subject to all the actions provided for by the legal system to protect the Company, including disciplinary procedures and the application, in compliance with the principles of graduality and proportionality, of the related sanctions.