Sustainability
Sustainability: the ESG policy and code of ethics of Alchemyst LAB
On 19 October 2026 Alchemyst LAB, the company behind Alchemyx, adopted a Sustainability Policy with ten measurable targets for 2026-2027 and a Code of Ethics and Conduct. On this page you will find the texts, the documents to download and the channel for reporting concerns.
Four commitments, made from day one
Environment
Remote work, zero paper, cloud in low-emission regions and efficient use of artificial intelligence models. First carbon footprint estimate for cloud and AI services by 30 June 2027.
People
Equal opportunities at every stage of the relationship, hiring with written criteria, recorded training, guidelines for screen-based and remote work, right to disconnect.
Suppliers
Ethics and ESG clause in every new contract from 1 November 2026 and ESG self-assessment of the main suppliers (cloud, AI, development) by 30 September 2027.
Governance
The Sole Director is accountable for ESG matters, reviews the targets every six months and reports to the shareholders every year. ESG profile measured on Open-es and submitted to third-party verification.
The social mission of the product
Multichannel advertising (radio, television, cinema, digital out-of-home, social media, search engines) is today mostly within reach of companies with large budgets and dedicated teams. Alchemyx makes it accessible to small and medium-sized businesses: AI-assisted planning, package prices with no hidden costs, no spending without approval, refundable funds.
At the same time it brings new demand to local media (regional radio and TV stations, cinemas, digital networks), which Alchemyst LAB represents under sales mandates while protecting their prices and commercial policies. Making advertising accessible to SMEs and supporting local news and entertainment are the positive impacts the company pursues through its business model.
The Sustainability Policy and the 2026-2027 ESG targets
Document ALAB-ESG-02, revision 1.0 of 19 October 2026, approved by the Sole Director. It applies to shareholders, contributors and suppliers. Below is the full text, reorganised for reading on the web; the signed original is in Italian.
Alchemyst LAB S.r.l. is an innovative startup based in Milan, incorporated in 2025. It is a micro-enterprise with no employees: the work is done by the operating shareholders and external contributors, mostly remotely, on cloud infrastructure. The Alchemyx platform is in beta until December 2026, with Early Access reserved for selected SMEs. The Policy sets out the principles, operating guidelines and measurable targets through which the company builds environmental, social and governance (ESG) sustainability into its activities from the start-up phase.
Environment: climate, energy, resources
The company owns no vehicles, facilities or warehouses and has no energy contracts in its name; it has no production processes, uses no water for industrial purposes and generates no process waste. Direct emissions (Scope 1) are zero; indirect emissions from purchased energy (Scope 2) cannot be measured because no utility contract is in the company’s name; the most relevant emissions are those in the value chain (Scope 3), in particular cloud and artificial intelligence services and travel.
- Remote work as the normal way of working and remote meetings; travel only when necessary, preferring rail to air and car on domestic routes.
- Fully paperless: digital documents, contracts and signatures, no printing unless required by law.
- Cloud infrastructure: with equal performance and data requirements, preference for regions and providers with low-emission energy and emissions reporting; resources sized to actual needs, unused environments switched off.
- Efficient use of artificial intelligence models: the right model for each task, reuse of results, limits on repeated generations.
- Electronic equipment: bought only when needed, used for a long time, repaired where possible, handed over at end of life as WEEE through authorised collection channels. No hazardous substances.
- Digital product, no packaging.
People: equal opportunities, training, health and safety
- Equal opportunities and non-discrimination at every stage of the relationship, following the hiring guidelines in the Code of Ethics: role described in writing, objective documented criteria, no questions about private life, equal pay for equal work.
- Ongoing team training on artificial intelligence, regulation (AI Act, GDPR, advertising), cybersecurity and ESG topics, recorded in the Training Register.
- Wellbeing: flexible hours, right to disconnect, sustainable workload.
- Health and safety: guidelines for screen-based and remote work (workstation, breaks, lighting), basic training, obligations under Italian Legislative Decree 81/2008 from the first hire.
Supply chain
The main suppliers are cloud and artificial intelligence services, an external software development provider and professionals (accountant, legal advisers).
- Clause of adherence to the Code of Ethics and to the principles of legality, labour protection, human rights and the environment in every new contract.
- Preference for suppliers with published ESG policies.
- Within one year, ESG self-assessment of the main suppliers through a simple questionnaire, updated every year.
Governance and integrity
The Sole Director is responsible for ESG matters, approves the Policy and the targets, reviews progress every six months and reports to the shareholders at least once a year at the general meeting and in periodic meetings. The company uses the Open-es platform to measure and report its ESG performance, updates its profile every year and submits it to third-party verification. The Code of Ethics and the Anti-corruption and Whistleblowing Procedure complete the system. The company is registered with the ROC (no. 43945), meets the innovative startup requirements verified by the Chamber of Commerce and is a member of Assolombarda.
Relevant ESG risks and opportunities
For each topic, the risk identified and the safeguard adopted.
Personal data and cybersecurity
Risk: Breach of client data, unauthorised access, GDPR penalties.
Safeguard: Published privacy notices, access controls, separated environments, no transfer of data; path towards ISO 27001 in the medium term.
Use of artificial intelligence
Risk: Discriminatory or misleading content, lack of transparency, non-compliance with the AI Act.
Safeguard: Human oversight on every campaign, anti-bias checks, labelling of synthetic content, team training, public «Responsible AI» manifesto.
Climate and energy
Risk: Unmeasured indirect emissions from cloud and AI; growing expectations from clients and investors.
Safeguard: Carbon footprint measurement of cloud services, choice of low-emission regions, remote work; a competitive advantage with clients and in tenders.
People and team growth
Risk: Dependence on a few key people; risk of non-inclusive hiring as the team grows.
Safeguard: Neutral hiring criteria already defined, ongoing training, flexible work that widens the talent pool.
Integrity and reputation
Risk: Unlawful advertising content carried by the platform; conflicts of interest; corruption.
Safeguard: Excluded sectors in the Terms and Conditions, human approval, Code of Ethics, Anti-corruption Procedure, whistleblowing channel.
Supply chain
Risk: Foreign suppliers with no safeguards on labour and environmental issues.
Safeguard: ESG clause in contracts, self-assessment of the main suppliers, preference for suppliers with published policies.
ESG targets 2026-2027: indicators, goals and deadlines
1. Measure the carbon footprint of cloud and artificial intelligence services (Scope 3)
Indicator: Estimated tCO2e for 2026 using cloud provider data
Goal: First estimate published internally
Deadline: 30/06/2027
2. Reduce the emissions intensity of the cloud
Indicator: Share of workloads in low-emission cloud regions
Goal: At least 80%
Deadline: 31/12/2027
3. Zero paper and sustainable mobility
Indicator: Printed documents; share of domestic trips by rail
Goal: 0 prints unless required; rail at least 80%
Deadline: Ongoing, reviewed 31/12/2026
4. Record team training
Indicator: Training Register in place; hours per person per year, of which on ESG topics
Goal: Register from 01/11/2026; at least 8 hours per person in 2027, of which at least 2 on ESG
Deadline: 31/12/2027
5. Inclusive hiring
Indicator: Hiring processes run with written, documented criteria
Goal: 100% of hiring processes
Deadline: From the first hire
6. ESG clause with suppliers
Indicator: New supply contracts with an ethics and ESG clause
Goal: 100% of new contracts
Deadline: From 01/11/2026
7. ESG self-assessment of the main suppliers
Indicator: Main suppliers (cloud, AI, development) with a completed self-assessment
Goal: At least 3 suppliers
Deadline: 30/09/2027
8. Verified ESG profile
Indicator: Open-es profile complete and verified by a third party; annual update
Goal: Verification obtained
Deadline: 31/12/2026, then every year
9. Reporting to shareholders on ESG
Indicator: Report from the Sole Director to the shareholders on progress against the targets
Goal: At least once a year
Deadline: By the annual accounts meeting
10. Information security
Indicator: Gap analysis against ISO 27001 and remediation plan
Goal: Analysis completed
Deadline: 31/12/2027
Action plan, responsibilities and review
The Sole Director is responsible for implementation, supported by the CTO shareholder for the technical targets (1, 2 and 10) and by the development provider for collecting cloud consumption data. For each target the plan provides for: baseline data collected by 31 December 2026, half-yearly progress review (June and December), Open-es profile update, annual report to the shareholders. The Policy is reviewed at least once a year and updated when activities, organisation or regulation change; from the first hire it will be supplemented with the obligations on employment, health and safety.
The Code of Ethics and Conduct
Document ALAB-ESG-01, revision 1.0 of 19 October 2026. It applies to the Sole Director, shareholders, contributors and consultants, future employees and, where compatible, suppliers, who receive it or find it referenced in their contracts. These are its principles; the full text is in the PDF (in Italian).
The principles of the Code of Ethics
Legality
Compliance with the laws of the countries where we operate: company law, tax, employment, data protection, advertising, competition and artificial intelligence (Regulation (EU) 2024/1689, the «AI Act»).
Integrity and transparency
Relations with clients, media, agencies, suppliers, investors and institutions based on fairness and good faith. Information shared externally is truthful and verifiable.
Responsibility and confidentiality
Every decision considers its impact on people, the environment and communities. Confidential information of the company, clients and suppliers is protected and used only for the purposes for which it was obtained.
Human rights and equal opportunities
Respect for the Universal Declaration of Human Rights and the ILO Conventions; no forced or child labour, including in the supply chain. No discrimination based on gender, age, origin, religion, opinions, orientation, disability or personal circumstances, in hiring, assignments, pay, training and career growth.
Health, safety and wellbeing
Suitable workstations, regular breaks, basic training on screen-based work, sustainable workload. From the first hire, the obligations under Italian Legislative Decree 81/2008.
Personal data and information security
Processing in line with the GDPR. Client data is never sold or transferred: it is shared with artificial intelligence providers only to generate the requested creatives and, where available, with settings that exclude model training.
Responsible use of artificial intelligence
Transparency towards clients and users, human oversight on every campaign before activation, traceable media plans, checks against discriminatory or misleading content, labelling of synthetic content (Art. 50 AI Act), AI literacy for the team (Art. 4 AI Act).
Clients, media, agencies and suppliers
No spending without the client’s approval, refundable funds, package prices with no hidden costs; excluded sectors (gambling, tobacco, weapons, adult content, political propaganda, pyramid schemes). With media, written sales mandates and protection of the publisher’s prices. Suppliers chosen for competence, reliability, security and respect for the Code.
Anti-corruption and conflicts of interest
Any form of corruption, active or passive, towards public or private parties is forbidden. Only courtesy gifts of modest value (up to 50 euros), never cash. Anyone with a conflict of interest discloses it to the Sole Director and abstains.
Environment
Remote work, paperless documents and signatures, cloud infrastructure, proper handling of electronic equipment at end of life. The measurable targets are in the Sustainability Policy.
Implementation and oversight
The Sole Director oversees the application of the Code, promotes it and reports to the shareholders at least once a year. Breaches lead, in proportion to their seriousness, to warnings, termination of contracts and the measures provided by law. Reviewed at least annually.
How to report a breach
Anyone who becomes aware of a breach, even a suspected one, of the Code of Ethics or of the law can report it by writing to info@alchemystlab.com with the subject «Segnalazione riservata» (confidential report), or by post to the registered office (Piazza Castello 19, 20121 Milan, Italy) for the attention of the Sole Director.
Reports can be anonymous. The company guarantees the confidentiality of the reporter’s identity and forbids any retaliation against them. Reports are handled under the Anti-corruption and Whistleblowing Procedure.
Download the documents
- PDFWeb versions of the documents adopted on 19 October 2026, signed in the original. The documents are in Italian.
- Sustainability Policy and ESG targets 2026-2027ALAB-ESG-02, rev. 1.0, PDF, 3 pages, in Italian · Download the PDF
- Code of Ethics and ConductALAB-ESG-01, rev. 1.0, PDF, 3 pages, in Italian · Download the PDF
- Other documentsOur Responsible AI manifesto, privacy policy and cookie policy are also public.
We measure our ESG performance on Open-es
Alchemyst LAB measures and reports its ESG performance on Open-es, the digital platform promoted by Eni for supply chain sustainability, based on the European standard for small businesses (VSME). The profile is updated every year and submitted to verification by an independent third party.
October 2026 update: ESG documents adopted on 19 October 2026; Open-es profile completed in the Fundamentals, Maturity and Master classes; ESG clause in new supply contracts and Training Register in place from 1 November 2026; third-party verification planned by 31 December 2026. Open-es
Questions about the Policy or the Code of Ethics?
Write to info@alchemystlab.com. To learn more about the company, the team and the startup programs it belongs to, visit the Company page. Documents adopted on 19 October 2026. Page updated on 21 October 2026.
Frequently asked questions
Why does a startup with no employees adopt an ESG policy?
To set the rules before growing. Hiring criteria, supplier clauses, data management and the use of artificial intelligence are written down now, while the team is small, and apply to every person and contract that is added.
Does Alchemyst LAB measure its emissions?
Direct emissions are zero: the company has no vehicles, facilities or utility contracts in its name. The most relevant emissions are the indirect ones from cloud and artificial intelligence services: the first estimate in tCO2e for 2026 is planned by 30 June 2027, using cloud provider data.
Is client data sold or used to train AI?
No. Client data is never sold or transferred. It is shared with artificial intelligence service providers only to generate the requested creatives and, where available, with settings that exclude model training.
How do I report a breach of the Code of Ethics?
Email info@alchemystlab.com with the subject «Segnalazione riservata» or write by post to the registered office, for the attention of the Sole Director. Reports can be anonymous; the reporter’s identity is kept confidential and any retaliation is forbidden.
Who is responsible for ESG at Alchemyst LAB?
The Sole Director: approves the Policy and the targets, reviews progress every six months and reports to the shareholders at least once a year. The CTO shareholder supports the technical targets.
Does Alchemyst LAB hold ESG certifications?
Not yet. The ESG profile on Open-es is complete and verification by an independent third party is planned by 31 December 2026. In the medium term a gap analysis against ISO 27001 for information security is planned.