Code of Ethics · Forensis Lab

Courtesy translation for ease of reading. The Italian text is the binding version; legal references are to Italian law. Full text in Italian

Foreword

Forensis Lab is a forensic and anti-counterfeiting consultancy laboratory specialising in perfumery and cosmetics. Its work produces documents that may enter court proceedings, guide a company's decision, reassure or alarm a consumer. That is why the way we work matters as much as what we know how to do.

The Manifesto «The scent of legality» says what we believe in. This Code of Ethics says how we behave: which rules we follow, what we refuse, how compliance is verified. It is a commitment made to the judicial authority, law enforcement, brands, retailers, consumers, schools and the technical partners we work with.

The Code does not replace the law, the duties attached to registration in the court experts' register or the obligations undertaken with each individual engagement: it complements them and, where possible, goes further.

1Scope

1.1Addressees: The Code applies to the founder, collaborators in any capacity, trainees, consultants, technical partners (third-party laboratories, law firms, forensic economists), suppliers and anyone acting in the name or on behalf of Forensis Lab (hereinafter the «Addressees»).
1.2Acceptance: Working with Forensis Lab entails acceptance of the Code. Technical partners and suppliers receive the Code when the engagement is awarded; agreements with them refer to the obligation to comply with it (Annex A).
1.3Precedence: Where the Code conflicts with a practice, an industry custom or an instruction received, the Code prevails. Where the Code conflicts with the law, the law prevails.
1.4Extent: The Code applies to every activity: expert reports and technical consultancy, investigative support, training, brand consultancy, the digital pre-analysis platform, the retailer attestation programme, educational activities and communication.

2General principles

2.1Legality: Forensis Lab operates in compliance with Italian and European law and with the orders of the authorities. Legality is not a minimum requirement but the very object of our work: we do not allow it to be pursued by illegal means.
2.2Independence and impartiality: Technical judgement is not influenced by the client, the fee, personal relationships or economic interests. Forensis Lab does not manufacture, distribute or sell the products it examines.
2.3Truth and rigour: Every conclusion rests on verifiable elements obtained with a declared, repeatable method. What is not proven is not asserted.
2.4Competence: We accept only engagements within our competence and within the limits of our instruments. We maintain and update our skills through continuous training.
2.5Confidentiality: Information received in the course of our work is protected. Secrecy over investigative acts is a legal obligation, not a courtesy.
2.6Transparency about limits: We state in advance what we cannot do, or cannot do in the specific case. A declared limit is worth more than a vague promise.
2.7Protection of people and health: A counterfeit product is potentially dangerous for those who use it. Consumer health prevails over every commercial interest, including our own.
2.8Accountability: Every document issued by Forensis Lab has an identifiable author who answers for what they have written.

3Expert work

3.1Accepting an engagement

a)Before accepting an engagement we verify the absence of conflicts of interest (section 6.3), the availability of the necessary skills and instruments, and the lawfulness of the purpose declared by the client.
b)We refuse engagements that require a predetermined outcome, that serve to intimidate, denigrate or harm third parties without foundation, or that would result in the dissemination of techniques useful for counterfeiting.
c)The engagement is documented in writing, with subject, samples, level of analysis requested, timing and limits.

3.2The sample and the chain of custody

a)An expert report is written only on samples physically examined. Photographs, descriptions, technical sheets or images transmitted remotely may support a pre-analysis, never an expert report.
b)Every sample is identified, photographed, described in the state in which it was received and recorded with date, origin and mode of delivery. The chain of custody is documented without interruption until return or disposal.
c)In judicial contexts the report is always accompanied by the attached technical sheet, which states the method, the comparisons performed, the instruments used and the identification of the samples.
d)Samples are not altered beyond what the analysis requires. When an analysis is destructive, the client and, where applicable, the authority are informed before it is carried out.
e)Reference samples used for comparisons have a documented origin.

3.3Method and levels of analysis

a)The method is organised in three levels: assisted pre-analysis on images and codes (L1), comparative physical verification against reference samples (L2), instrumental chemical analysis (L3). Every report states at which level the analysis stopped and why.
b)First-level pre-analysis, even when assisted by artificial-intelligence tools, is a screening: it guides the decision to proceed, has no value as an expert report and is not presented as such.
c)Third-level instrumental analyses are performed at the Forensis Lab laboratory or at qualified third-party laboratories. In every case the report states who performed the analysis, with which instrument and by which method. Forensis Lab does not attribute to itself analyses performed by others.
d)Forensis Lab declares the accreditation and certification status of its own laboratory and of the third-party laboratories it uses. Accreditation under UNI CEI EN ISO/IEC 17025 is a declared objective: until it is achieved it is neither claimed nor implied.
e)Substances detected are also assessed in the light of the obligations of Regulation (EC) 1223/2009 on cosmetic products, with particular regard to substances that are prohibited, restricted or subject to labelling.

3.4Drafting and signature

a)The report clearly distinguishes observed facts, analysis results, assessments and conclusions. Hypotheses are presented as hypotheses.
b)Conclusions state the degree of certainty reached and the limits of the analysis. An outcome is not softened, emphasised or omitted to please the client or for fear of their reaction.
c)The report is signed by its author, with name, surname and qualification. No one signs for others. The report carries a unique code that allows it to be verified.
d)The language is understandable to the recipient: a report the client cannot understand does not fulfil its function.
e)A doubt is not turned into an accusation. The report establishes whether a product is compliant or not; attributing responsibility is for the competent authority.
f)Expert reports, findings and supporting documentation are kept for ten years or for the longer period required by law or by the proceedings.

3.5Use of artificial intelligence

a)Artificial-intelligence tools are used to support screening, comparison and document management. No outcome is issued without the assessment of a person who takes responsibility for it.
b)The use of automated tools is declared in the documents where it affects the result.
c)Clients' images and data are not used to train third-party systems without an adequate legal basis and privacy notice (section 4).
d)Forensis Lab periodically verifies the reliability of the tools used and documents their known limits.

3.6Relations with the judicial authority and law enforcement

a)Forensis Lab acts as an auxiliary to the judicial police (art. 348, para. 4, of the Italian Code of Criminal Procedure, c.p.p.), technical consultant (art. 359 c.p.p.; art. 61 of the Code of Civil Procedure, c.p.c.) or court expert (art. 220 et seq. c.p.p.) exclusively on formal appointment by the competent authority, within the limits and for the duration of the appointment.
b)In the appointment we observe the duties of truth, diligence and impartiality and the obligations of secrecy over investigative acts (art. 329 c.p.p.), aware of the criminal consequences of a false expert report (art. 373 of the Criminal Code, c.p.) and of the unjustified refusal of office (art. 366 c.p.).
c)Grounds of incapacity or incompatibility (art. 222 c.p.p.) and any circumstance that may affect impartiality are communicated to the authority before acceptance.
d)Forensis Lab does not present itself, in any communication, as a body, branch or institutional partner of law enforcement, customs or public prosecutors. It does not use institutional logos, names, symbols or uniforms. Collaborations are cited only when they can be documented, in the terms in which they took place and with due confidentiality.
e)Information acquired in an appointment by the authority is not used for commercial purposes, for brand consultancy or for communication.

3.7Relations with brands and private clients

a)A private client receives the same method and the same rigour as the judicial authority. The outcome does not depend on who pays.
b)The fee is set before the engagement and is never linked to the outcome of the analysis, the number of non-conformities found or the value of the estimated damage.
c)Forensis Lab does not accept engagements that would place it, on the same product or the same matter, at the service of opposing parties, unless all parties give informed written consent.
d)Economic damage estimates are prepared with associated law firms and forensic economists, named in the document, on the basis of verifiable data and declared assumptions.
e)Market monitoring does not involve unauthorised access to computer systems, use of false identities in breach of the law, or collection of personal data without a legal basis.

3.8Relations with consumers

a)Consumers are given clear, truthful, non-alarmist information. The distinction between pre-analysis and expert report is explained in plain terms before any request.
b)The outcome of an analysis is communicated with the same care whether it confirms or excludes authenticity.
c)Forensis Lab does not lead consumers to believe that an image-based pre-analysis has evidential value and does not steer them towards unnecessary analyses.
d)Consumers' personal data are processed in accordance with section 4. Images uploaded to the platform are used only for the declared purposes.
e)When an analysis reveals a health risk, Forensis Lab informs the client of the possibility of reporting to the competent authorities and, in the cases provided for by law, makes the report.

3.9Retailer attestation programme

a)The attestation is issued to the business, not to the individual product, on the basis of standardised verification protocols and audits on samples taken from the point of sale. It is earned, renewed and lost.
b)The fee pays for the audit, not the result. No attestation is conditional on payment of sums linked to the outcome.
c)Whoever performs the audit has not provided paid consultancy or training to the audited retailer in the previous twelve months and has no economic or personal relationship with it.
d)The attestation has an expiry date, is recorded in an immutable and verifiable way and is published in a register available to consumers. Suspension and revocation are published with the same prominence as the award.
e)When the programme is structured as a certification mark, under art. 11-bis of the Italian Industrial Property Code (Legislative Decree 30/2005) or Regulation (EU) 2017/1001, Forensis Lab adopts public regulations of use and maintains the condition of not supplying the certified products.
f)Any consumer reviews incorporated in the programme are collected and published in compliance with Legislative Decree 26/2023 (Omnibus Directive), with verification of origin and without misleading selection.
g)Until the programme is complete, Forensis Lab does not issue attestations, seals or badges and does not allow its name to be used as a guarantee by retailers.

3.10Training and legality education

a)Training content is accurate, up to date and suited to the audience. Recognition techniques are passed on according to need: details that would facilitate counterfeiting are not disclosed.
b)Teaching materials do not reproduce brands or products beyond what the educational purpose requires and do not imply approval by the trademark owners.
c)In activities with schools Forensis Lab works in agreement with the institutions and in compliance with the rules protecting minors: it does not collect images or data of pupils without the required authorisations and does not use educational activities as a promotional vehicle.
d)Educational activities are not presented as initiatives of law enforcement or of the bodies taking part, unless this results from formal agreements.

4Confidentiality, personal data and intellectual property

4.1Professional secrecy: Information received from clients, analysis results, reference samples and brands' technical information are treated as confidential, also after the end of the engagement and of the working relationship.
4.2Personal data: Personal data are processed in compliance with Regulation (EU) 2016/679 and Legislative Decree 196/2003: declared purposes, minimisation, privacy notice, adequate security measures, defined retention periods and exercise of data subjects' rights. Data acquired in appointments by the authority follow the rules of the proceedings.
4.3Images and comparative database: Sample photographs and collected data feed the Forensis Lab comparative database in a form that cannot be traced back to the client, unless consent is given or the law requires otherwise. The database is not transferred to third parties.
4.4Intellectual property: Forensis Lab respects brands' trademarks, copyright and trade secrets. Original samples, sheets and technical information received for comparisons are used only for the purpose for which they were provided. Forensis Lab's methods, protocols and materials are protected and are not transferred without a written agreement.
4.5Information security: Information is stored on protected systems, with access limited to those who need it. Confidential communications with the authority and with clients take place through traceable, secure channels.

5Communication and use of the brand

5.1Truth: Forensis Lab's communications are truthful, verifiable and not misleading. Statements that cannot be fully proven are introduced by «to our knowledge» or equivalent wording.
5.2Titles and qualifications: Titles, registrations, certifications and accreditations are cited only if actually held, in the exact terms in which they are held. Trademark registration symbols are used only after registration.
5.3Institutions and third parties: Forensis Lab does not use logos, names or symbols of institutions, law enforcement, bodies or brands in a way that suggests an affiliation, approval or sponsorship that does not exist.
5.4Competitors and third parties: Communication does not denigrate competitors, brands, retailers or products. Analyses of market phenomena («dupe» products, testers, parallel channels) distinguish what is unlawful from what is lawful and do not attribute unlawful conduct without proof.
5.5Cases and results: Cases handled are cited only anonymously or with the authorisation of those concerned and, if pending, in compliance with the secrecy of the proceedings. No images or data are disseminated that would allow a proceeding or a client to be identified.
5.6Social media: Whoever speaks about Forensis Lab on social media does so with the same correctness required of official communications. Personal opinions are kept distinct from the laboratory's positions.

6Business integrity

6.1Corruption: Forensis Lab does not offer, promise, give, request or accept, directly or indirectly, money or other benefits to obtain or retain an engagement, influence an outcome or gain an undue advantage, whether towards public officials and persons in charge of a public service (art. 318 et seq. of the Italian Criminal Code) or between private parties (art. 2635 of the Civil Code).
6.2Gifts and hospitality: Only gifts and hospitality of modest value are allowed, occasional, never in cash and never in connection with an ongoing engagement or an outcome. Gifts beyond that measure are refused or returned and, where that is not possible, handed over to the Ethics Officer.
6.3Conflicts of interest: Before the engagement every Addressee reports any economic interest or professional or personal relationship with the parties, products or brands involved. Forensis Lab keeps a register of declared conflicts and of the decisions taken (Annex B). No Addressee examines products or assesses retailers in which they have, or have had in the previous twelve months, an economic interest.
6.4Technical partners and suppliers: Third-party laboratories, law firms, forensic economists and suppliers are chosen for competence, reliability and integrity and, where relevant, for verified qualifications and accreditations. They are informed of the Code and of the confidentiality rules. No commissions are paid or received for referring engagements.
6.5Accounting and payments: Every transaction is recorded truthfully, completely and traceably. Cash payments beyond legal limits, payments to persons other than the contractual counterparty, and invoices for services not performed are not allowed.
6.6Fair competition: Forensis Lab competes on the quality of its method, not on denigrating others, on unlawfully acquiring information or on practices prohibited by art. 2598 of the Italian Civil Code.

7People, safety and the environment

7.1People: Working and collaborative relationships are based on respect, equal opportunities and the development of skills. Discrimination, harassment, abuse of position or conduct harmful to dignity are not tolerated.
7.2Laboratory safety: Counterfeit products may contain hazardous substances. Samples are handled with protective equipment, in suitable environments and according to written procedures, in compliance with occupational health and safety law (Legislative Decree 81/2008). No sample is tested on people.
7.3Custody and disposal: Samples are stored so as to prevent their dispersal or return to the market. Non-compliant samples and analysis materials are disposed of as waste under current law (Legislative Decree 152/2006), with documentation of disposal. No product subject to an expert report is given away, sold or reused.
7.4Environment: Forensis Lab reduces the impact of its activities: responsible use of solvents and reagents, digitalisation of documentation, travel limited to what is necessary.
7.5Supply chains and human rights: Forensis Lab refuses any collaboration with parties that resort to child labour, forced labour or exploitation, and regards the fight against counterfeiting also as a fight against the supply chains that feed on it.

8Social commitment

8.1Culture of legality: Forensis Lab promotes the culture of legality through education, training and the dissemination of accurate information on the risks of counterfeiting, without alarmism and without exploiting institutions, schools or minors.
8.2Independence of initiatives: Social initiatives are not conditional on commercial returns and are reported transparently.

9Implementation, reports and sanctions

9.1Ethics Officer: The founder appoints an Ethics Officer responsible for disseminating the Code, answering questions of interpretation, receiving reports, keeping the register of conflicts of interest and proposing updates. Until the appointment, these functions are carried out by the founder.
9.2Dissemination and training: The Code is published on the Forensis Lab website, given to every Addressee and explained in a training session at the start of the collaboration and at every revision.
9.3Reports: Anyone may report, also anonymously, breaches of the Code or of the law through the website contact form, with the subject «Ethics report», or by writing to forensislab@pec.it. Reports are handled confidentially; whoever reports in good faith is protected from retaliation, in line with the principles of Legislative Decree 24/2023, which Forensis Lab adopts voluntarily regardless of size thresholds. Unfounded reports made with intent constitute a breach of the Code.
9.4Checks: The Ethics Officer periodically verifies compliance with the Code through sample checks on engagements, reports, chain of custody and communications, and reports to the founder at least once a year.
9.5Sanctions: A breach of the Code constitutes non-fulfilment of the obligations undertaken and may lead, in proportion to its seriousness, to: a written warning, exclusion from specific engagements, termination of the collaboration or of the contract, reporting to the competent authorities where the conduct is legally relevant. If the breach concerns an expert report already issued, Forensis Lab informs the client and, where applicable, the authority.
9.6Revision: The Code is reviewed at least once a year and in any case when the legal framework, the services or the organisation change. Every revision is dated and numbered. The next revision is scheduled for September 2027.

10Final provisions

10.1Entry into force: The Code enters into force on the date of adoption and is available on the website and at the Forensis Lab premises.
10.2Reference: For anything not provided for, the law, the duties attached to registration in the court experts' register and the contractual obligations undertaken apply.

Revision 1 · September 2026 · being adopted

Alessandro Pette

Founder

Signature

Annexes

Annex A · Declaration of acknowledgement and acceptance

The undersigned ______________________, as a collaborator, consultant, technical partner or supplier of Forensis Lab, declares:

a)to have received and read the Forensis Lab Code of Ethics, Revision 1, September 2026;
b)to accept its contents and to undertake to comply with them within the relationship with Forensis Lab, including the provisions on confidentiality (section 4) and conflicts of interest (section 6.3);
c)not to have, as of today, economic interests or professional or personal relationships in conflict with the activities entrusted, or to have declared them in writing to the Ethics Officer;
d)to be aware that a breach of the Code may lead to the consequences set out in section 9.5.

Place and date
Signature of the declarant

Annex B · Register of conflicts of interest

The register is kept by the Ethics Officer and updated at every declaration. The possible decisions are: no conflict, conflict managed with the measures indicated, abstention from the engagement, refusal of the engagement.

Date	Addressee	Engagement / activity	Nature of the declared conflict	Ethics Officer's decision	Signature

Reference template · Rev. 1 · September 2026

The Manifesto says what we believe in. Read the manifesto