Code of Ethics

Approved by resolution of the Board of Directors of 29/04/2022


The Code of Ethics (hereafter the “Code”) is an official document of Braviisol D.M. srl (hereinafter
the “Company”) approved by the Board of Directors that contains all principles and rules of conduct
to which all those who work in the business environment and with the Company are required to
comply with.
The purpose of this Code is to articulate and disseminate principles and rules of conduct that
Braviisol D.M. srl will constantly refer to within the scope of their business operations


This Code is binding and must be observed by all operating employees of the Company or by any
person who carries out activities in the name and/or on behalf of the Company, wherever they
operate in Italy and abroad, including persons with functions of representation, administration or
management of the Company, by the members of the Board of Statutory Auditors, the Independent
Auditors and by the external collaborators and consultants who act in the interest of the Company.


The task of supervising the compliance with the Code is assigned to a person identified among the
internal staff and appointed by the Board of Directors. The Guarantor monitors the actual
dissemination and understanding of the Code within the Company and the correct and effective
implementation of the principles set out in the Code.


This Code has been approved and adopted by resolution of the Company Board of Directors on April,
29 2022 with effect from the same date.
This Code is available on the Company’s website, on the Intranet and on the Company bulletin


In performing their activities, the Company acts according to the principles of legality, correctness,
fair competition and transparency towards all stakeholders on the market.
In fulfilling their work and contractual duties, all persons required to conform with this Code will act
with impartiality and neutrality and take decisions strictly and transparently, in full compliance with
the law.
All the staff of the Company will avoid any situation or activity that might give rise to conflicts of
interest with Braviisol D.M. srl or might interfere with their ability to make independent decisions.
In this regard, the employees of the Company will not use their position within the Company or the
information acquired while performing their working activities in order to create, even potentially,
conflicts between their private interests and the interests of the Company. Moreover, without
prejudice to the provisions of the applicable regulations about contracts, the employees of the
Company must not take on external positions in companies or commercial businesses whose
interests are directly or even potentially conflicting or interfering with those of Braviisol D.M. srl


In accordance with the Conventions of the International Labour Organization (ILO), the OECD and
United Nations Guiding Principles on Business and Human Rights (UNGPs), applicable laws and
National Collective agreements for the protection of working conditions, the Company is committed
to respecting fundamental human rights by adopting an ethical and social responsibility policy as
expressed by this Code.
In particular, the Company:
• avoids any form of discrimination against its employees and offers equal opportunities to all
employees, ensuring that they can all benefit from fair treatment based on merit and in full
compliance with the law, without any discrimination on grounds of gender, political beliefs,
race, sexual orientation etc.;
• select and hires its employees, ensuring full compliance with the values of equal
opportunities and equality in accordance with the provisions of the applicable laws, with the
Workers’ Statute and the applicable national collective bargaining agreements;
• rejects and opposes any form of slavery and forced labour, ensuring the workers’ right of
self-determination while respecting the legal work requirements provided for the
completion of company activities;
• rejects child labour, in accordance with applicable national and international laws;
• rejects any form of coercion of the employees, forbidding the provision of guarantees or the
payment of sums of money to gain access to the labour market, as well as the delivery and/or
deposit with the employer of IDs, residence permits or other personal items;
• ensures employees the freedom of self-determination regarding food and personal
accommodation and transportation to work;
• creates a working environment where the personal characteristics of the individual worker
do not give rise to discrimination;
• ensures the protection of personal data regarding its employees and their right to work
without being unlawfully influenced;
• makes sure that internal and external work relationships do not give rise to reduction or
maintenance in a state of submission through violence, threat, deceit, abuse of power,
exploitation of situation of physical or mental worthlessness or a situation of necessity or by promising or giving of sums of money or other benefits to those who have authority over
the person;
does not establish any employment relationship with non-EU citizens without a regular
residence permit and does not carry out any activity aimed at facilitating the illegal entry of
illegal immigrants into Italy;
• promotes a culture of workplace safety also through information and training workshops for
the staff and is committed to protecting the safety, health and moral integrity of its
employees, collaborators, consultants and suppliers. To this end, it promotes responsible
and safe behaviour, and adopts all safety measures required by technological evolution in
order to ensure a safe and healthy working environment, in full compliance with current
legislation on prevention and protection (Legislative Decree 81/08 and subsequent additions
and modifications);
• ensures that employee remuneration, including overtime pay, complies with current
legislation and the applicable National Collective Labor Agreement and is paid regularly and
on time as expected, by methods that allow everyone to collect it without any complications
or difficulties. It also ensures that no withholdings or deductions can be applied to
remuneration except in the cases expressly provided for by the Law or by the applicable
National Collective Labor Agreement;
• ensures and guarantees confidentiality and the correct processing of personal data
concerning its employees in compliance with the provisions of the GDPR 2016 and the
relevant Italian laws;
• promotes a culture of respect for the environment and has chosen to adopt an ISO14001
certified management system;
• promotes the training and information of its employees on the adopted ethical and social
responsibility policy, this Code of Ethics and on employment contracts, also in English;
• ensures that full compliance with the principles of this Code of Ethics by workers is never,
for them, a source of discrimination, disciplinary sanctions, dismissal or any type of threat
or intimidation.


The Company promotes and encourages:
• freedom of association and the right of collective bargaining without discrimination related
to membership of trade unions and/or membership of trade union activities;
• dialogue with trade union organizations, refraining from hindering or interfering with their
activities, giving it sufficient time and space;
• the activity and duties of employee representatives, who have the right to exercise their
representative functions without any intimidation or discrimination.
The Company considers reprehensible and offensive the following behaviours and therefore refuses
• work under the influence of excessive consumption of alcohol, drugs or substances with
similar effects;
• consume or sell drugs for any reason while at work;
• hold pornographic material and/or child pornography in any place that might be connected
to the Company;
• accept any acts of bullying, physical and psychological violence, harassment, sexual violence
and all forms of discrimination and gender-based violence, threats, insults and any action
that may cause distress or discomfort to the victim, even psychologically, or in any way that
undermines one’s dignity and decorum and/or limit one’s freedom of self-determination.


Documents, working tools, systems and equipment and any other tangible and intangible assets
(including intellectual property rights and trademarks) owned by the Company are used exclusively
for the achievement of business purposes, according to the methods defined by the Company; they
cannot be used by the employees for personal purposes, nor be compatible or made available to
third parties and must be used and kept with the same diligence as personal property.
Company assets also include business strategies and plans, customer lists, employee data,
marketing and sales plans, organization charts, product pricing policies, financial and accounting
data and any other information relating to the Company’s business, customers and employees.


Persons required to conform with this Code, in any capacity involved in bookkeeping, financial flows
and preparation of the financial statements, are required to comply with the rules (in the area of
anti-money laundering), including regulations relating to the truthfulness and clarity of data and
Employees are prohibited from replacing or transferring money, goods or other benefits deriving
from illegal activities; or carrying out other operations in relation to them, in order to hinder the
identification of their origin.
To this end, the Company and its employees must never carry out or be involved in activities that
imply the acceptance or processing of proceeds from crime, in any form or manner.
The Company expects its personnel to check, in advance, the available information (including
financial information) on commercial counterparties and suppliers in order to ascertain their
reliability and the legality of their activity, before establishing business relationships with them.


The Company shows a particular sensitivity in matters of health and safety in the workplace in order
to avoid the risks associated with the performance of the corporate activity. Expects its staff to
comply with all applicable legal obligations and, in particular:
• carries out adequate and periodic information/training for its staff on safety and health
matters, as well as carrying out drills and evacuation drills, ensuring that this
information/training is also guaranteed for new or reassigned workers;
• ensures that all employees operate in a safe workplace and that they have suitable
protective devices available;
• uses and maintains adequate safety devices;
• periodically checks the suitability of the offices and any other company premises, also with
reference to specific risks and with particular attention to the presence of vulnerable
workers, ensuring the correct conformity of workplaces to the legislative provisions on the
safety and health of workers and asks all employees to comply with the relevant provisions;
• ensures access to clean and functional toilets, drinking water and designated refreshment
areas for all staff and third-party visitors;
• requires that third parties working on its behalf guarantee the health and safety of workers
and third parties in carrying out the tasks assigned.
The recipients are invited to be as cooperative and helpful as possible towards anyone who carries
out inspections and checks on behalf of the Company and/or the responsible control bodies.
Company personnel must not expose other employees to risks that could cause damage to health
or physical safety.
All those who work for the Company are responsible for good management and compliance with
the procedures adopted about occupational health and safety.


In all relations with the Public Administration, Public Authorities and Public Institutions, the
Company is committed to fully and scrupulously implementing the applicable laws and regulations
and expects its employees to give, offer or promise money or other benefits or exercise unlawful
pressure against public officials, public service officers, executives, officials or employees of the
Public Administration or their relatives or cohabitants to induce them to carry out any act that is
compliant or contrary to their official duties.


The Company’s primary goal in dealing with customers is to increase the level of satisfaction and
appreciation for its services/products by becoming aware of the needs of customers, including
potential customers, and providing them with truthful, accurate, complete, and correct information.
Therefore, these relationships are managed in accordance with the principles of maximum
collaboration, professionalism, and transparency, as well as confidentiality and personal data
protection, in order to lay the groundwork for a solid and long-lasting relationship based on mutual
The Company bases its supplier selection on a careful technical-economic analysis that takes into
account the following parameters: product analysis; offer; suitability to ensure workplace health
and safety; economic convenience; technical and professional suitability; competence and
In the case of ongoing supply relationships, the Company maintains them on the basis of good faith
and transparency, as well as respect for the values of legality, fairness, impartiality, loyalty, and
equal opportunities.
In its interactions with external consultants, collaborators, partners, and business brokers, the
Company adheres to the same principles and selection criteria outlined in the preceding paragraphs.
In the event that the Company needs to make use of the professional services of Public
Administration employees as consultants, the legislation – including regulations in force must be
complied with.
The Company ensures and guarantees the confidentiality and correct processing of the personal
data of the stakeholders in compliance with the provisions of the GDPR 2016 and the applicable
Italian legislation.
The Company is committed to disclosing and disseminating this Code of Ethics to all its stakeholders,
in particular requiring its employees, suppliers and external collaborators to adhere to the principles
contained therein.


The Company will sponsor only events with cultural, sporting, or charitable value, with the goal of
enhancing existing initiatives in the area. Any sponsorships and contributions are guaranteed to be
The Company is committed to making donations only to duly formed associations, foundations,
public and non-profit bodies, in accordance with accounting, civil, and tax legislation, and in
accordance with the principles of maximum correctness and transparency.
Any donations are guaranteed to be traceable.


In drafting the financial statements and all other corporate communications required by law, the
company observes and asks its employees to:
• comply with applicable laws and accounting standards;
• to represent the company’s equity and financial status accurately and honestly;
Moreover, the Company forbids:
• the return of contributions made by the shareholder or releasing him from the obligation to
carry them out, except in cases of legitimate reduction of the share capital, even through
simulated conduct;
• approving profit distributions or advances on profits not actually achieved or intended for
legal reserves or distributing unavailable reserves;
• the fictitious formation or increase of the capital of the Companies, through the attribution
of shares for an amount lower than their nominal value, the decision to reciprocal
subscription of shares, the significant overvaluation of the contributions of assets in kind or
credits, or of the Company in the event of transformation;
• carrying out reductions in the share capital, mergers or demergers in violation of the
provisions of the law to protect creditors;
• the determination, with simulated or fraudulent acts, of fictitious majorities in the meetings
of the Company.


Recipients are obliged to observe and respect the principles of this Code and to comply with its rules
of conduct.
Knowledge of and adaptation to the provisions of the Code represent an indispensable requirement
for the purposes of establishing and maintaining collaborative and correct relationships with third
parties, towards whom the Company is committed to disseminating all connected information.
The violation of the provisions contained in this Code by suppliers, external collaborators, partners,
procurers and consultants are considered a serious breach by them and could constitute grounds
for termination of the contractual relationship.

Place and date
Castelfidardo, April 29th 2022