Code of Ethics

The Code of Ethics (hereafter: “Code”) is an official document of BRAVI-PLATFORMS S.R.L (hereafter also “The Company”), approved by the Board of Directors, which brings together the principles and rules of conduct to which all those who operate in the corporate environment and with the Company are subject. The purpose of this Code is to declare and disseminate the values and rules of conduct to which BRAVI-PLATFORMS S.R.L intends to make constant reference in the exercise of its business activities.

This Code is binding and must be observed by all personnel employed by the Company or by any person who performs activities in the name of and/or on behalf of the Company, wherever they operate, whether in Italy or abroad, including individuals who hold positions of representation, administration or management of the Company, members of the Board of Statutory Auditors, Auditing Firm, external collaborators and consultants who act in the interest of the Company.

Control over compliance with the Code is entrusted to a person identified from among the internal staff and appointed by the Board of Directors at the time of approval of this Code of Ethics, who will oversee the effective dissemination and understanding of the Code within the corporate fabric and the proper and effective implementation of the principles it contains.

This Code is approved and adopted, by act of the Company’s Board of Directors, on 29/04/2022with effect and efficacy on the same date.This Code is available for consultation on the Company’s website, intranet and Company Notice Board.

The Company, in the performance of its activities, operates according to principles of legality, fairness, fair competition and transparency with respect to all operators in the marketPersons required to comply with this Code, in the performance of their work and/or contractual services, operate with impartiality and neutrality and make decisions with rigor and transparency, in full compliance with the law.

All Company personnel must avoid situations or activities that could lead to conflicts of interest with Braviisol D.M. srl or that could interfere with their ability to make impartial decisions. In this regard, the personnel shall not use their position in the company and the information acquired in their work in such a way as to create, even potentially, a conflict between their personal interests and the interests of the company; furthermore, without prejudice to what is dictated by the relevant contractual regulations in force, the personnel of the Company shall not take on external assignmentsin Companies or commercial enterprises whose interests are directly or even potentially conflicting or interfering with those of Braviisol D.M. srl

In compliance with the Conventions of the International Labor Organization (ILO), the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the OECD, and current legislation and national collective bargaining agreements to protect working conditions, the Company is committed to respecting fundamental human rights, adopting the policy of ethical-social responsibility of which this Code of Ethics is an expression.

In particular, the Company:

• avoids any form of discrimination against its personnel and offers all workers equal opportunities, so that everyone can enjoy fair treatment based on merit and compliance with the law, without any discrimination on the grounds of sex, race, political opinion, sexual orientation, etc;
• takes care of the selection and hiring of employees, ensuring respect for the values of equal opportunity and equality in line with the relevant legal requirements, the Workers’ Statute and the applicable collective bargaining agreements;
• rejects and fights any form of servitude and forced labor, guaranteeing the freedom of self-determination of workers while respecting the legitimate work prescriptions given for the performance of company activities;
• rejects child labor, in accordance with current national and international regulations;
• rejects any kind of coercion of workers’ will, prohibiting the provision of security deposits or payment of sums of money in order to gain access to employment, as well as the handing over and/or depositing with the employer of identity documents, residence permits or other personal belongings;
• guarantees workers freedom of self-determination regarding personal food and lodging and means of transportation to the workplace;
• creates a work environment in which the personal characteristics of the individual worker do not give rise to discrimination;
• Ensures the protection and preservation of employees’ personal data and their right to work without unlawful influence;
• ensures that in internal and external labor relations there is no reduction or maintenance in a state of subjection through violence, threats, deception, abuse of authority, taking advantage of a situation of physical or mental inferiority or a situation of need, or through the promise or giving of sums of money or other benefits to those in authority over the person;
• does not establish any employment relationship with non-EU nationals without a regular residence permit and does not engage in any activity to facilitate the illegal entry, in Italy, of illegal subjects;
• promotes a culture of safety at work, including through information and training meetings directed at personnel; 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 behavior and adopts all safety measures required by technological evolution to ensure a safe and healthy working environment, in full compliance with current prevention and protection regulations (Legislative Decree 81/08 and subsequent additions and amendments);
• Ensures that the remuneration of personnel, including overtime, complies with the applicable Law and the applicable CCNL and is paid with the expected regularity and punctuality, through modalities that allow each person to collect it without any complications or difficulties. It also ensures that no deductions or deductions may be made from wages except in cases expressly provided for by Law or the applicable CCNL;
• ensures and guarantees the confidentiality and proper handling of employees’ personal data in compliance with the provisions of GDPR 2016 and current Italian law;
• promotes a culture of respect for the environment, having decided to adopt an Iso14001-certified management system;
• promotes training and information for workers on the adopted ethical-social responsibility policy, this Code of Ethics and the labor contract, including in English;
• ensures that workers’ full compliance with the principles of this Code of Ethics is never, for them, a source of discrimination, disciplinary sanction, dismissal or any kind of threat or intimidation.

The Company promotes and encourages:

• the freedom of association and the right of workers to collective bargaining without discrimination related to membership in trade unions and/or adherence to trade union activities;
• dialogue with trade union organizations, pledging not to hinder or interfere with their activities, guaranteeing adequate time and space;
• the activities and duties of workers’ representatives, who have the right to carry out their representative functions without any intimidation or discrimination.

The Company considers the following behaviors reprehensible and offensive and, therefore, rejects:

• serving under the effects of abuse of alcoholic substances, narcotics or substances having similar effects;
• consuming or disposing of drugs for any reason during the course of work;
• possessing in any place that can be traced back to the Company, pornographic and/or child pornographic material;
• acts of bullying, physical and psychological violence, harassment, sexual violence and any form of gender discrimination and violence, threats, insults and any other act that may cause
  in the victim a situation of suffering and/or discomfort, including psychological, or otherwise harm their dignity and decorum and/or limit in any way their freedom of self-determination.

Documents, working tools, equipment and facilities, and any other tangible and intangible assets (including intellectual property rights and trademarks) owned by the Company are used exclusively for the fulfillment of its institutional purposes, in the manner established by the Company; they may not be used by personnel for personal purposes, nor may they be transferred or made available to third parties, and they must be used and guarded with the same diligence as one’s own property.

Corporate assets also include, business strategies and plans, customer lists, personnel data, marketing and sales programs, organizational charts, product pricing policies, financial and accounting data, and any other information related to the Company’s business, customers and employees.

Individuals required to comply with this Code, in any capacity involved in the activities of bookkeeping, financial flows and budgeting, are required to comply with the rules (in the area of anti-money laundering), including regulations concerning the truthfulness and clarity of data and evaluations.

The Company prohibits employees from substituting or transferring money, goods or other utilities derived from unlawful activity; or carrying out other transactions in connection with them, so as to hinder the identification of their origin.

To this end, the Company and its employees must never carry out or be involved in activities such as to imply the acceptance or processing of income from criminal activities, in any form or manner.

The Company requires its personnel to verify, in advance, available information (including financial information) on business counterparties and suppliers in order to ascertain their trustworthiness and the legality of their activities, before establishing business relationships with them.

The Company shows particular sensitivity to occupational health and safety in order to avoid risks related to the performance of the Company’s activities.

It requires its personnel to comply with all applicable legal obligations and, in particular:

• carries out adequate and periodic information/training of its personnel on health and safety matters, in addition to carrying out evacuation drills and tests, ensuring that such information/training is also guaranteed for new or reassigned workers;
• ensures that all employees operate in a safe working environment and that they have at disposal suitable protective equipment;
• uses and maintains suitable safety equipment;
• periodically checks the suitability of offices and any other company premises, also with reference to specific risks and with particular attention to the presence of c. d. vulnerable, ensuring the proper adaptation of workplaces to the provisions
  legislation on the safety and health of workers and requires all staff to comply with the requirements in this regard;
• ensures that all staff and third-party visitors have access to clean and functional toilets, to drinking water and designated refreshment areas;
• requires third parties working on its behalf to ensure the health and safety of workers and third parties in the performance of the tasks entrusted to them.

The Company calls on all recipients to be helpful and cooperative with anyone who conducts inspections and audits on behalf of the Company and/or the supervisory agencies in charge.

Company personnel must not confront other employees with risks that could result in harm to health or physical safety.
All those who work for the Company are responsible for the proper management of and compliance with the procedures adopted for occupational health and safety.

In all dealings with the Public Administration, Public Authorities and Public Institutions, the Company undertakes to fully and scrupulously implement the applicable laws and regulations and prohibits its employees from giving, offering or promising money or other benefits or exerting unlawful pressure on public officials, public service appointees, managers, officials or employees of the Public Administration or their relatives or cohabitants to induce them to perform any act that complies with or is contrary to their official duties.

In its relations with its customers, the primary objective of the Company is to increase the degree of satisfaction and satisfaction with its services/products, raising awareness of the needs of customers, including potential ones, and providing them with true, accurate, complete and correct information.

Therefore, these relationships are managed according to principles of maximum cooperation, availability professionalism and transparency, respecting confidentiality and the protection of personal data in order to create the basis for a solid and lasting relationship of mutual trust.

In the selection of suppliers, the Company is based on a careful evaluation of technical and economic order in consideration of the following parameters: analysis of the products; the offer; suitability to guarantee health and safety at work; economic convenience; technical and professional suitability; competence and reliability.

In the force of continuous supply relationships, the Company maintains relationships marked by the principles of good faith and transparency and by respect for the values of legality, fairness, impartiality, loyalty and equal opportunity.
In relations with external consultants, collaborators, partners and procurers, the Company abides by the same principles and selective criteria as in the previous points.

In the event that the Company needs to make use of professional services of Public Administration employees as consultants, the laws – including regulations – in force must be complied with.

The Company ensures and guarantees the confidentiality and proper handling of stakeholders’ personal data in compliance with the provisions of the GDPR 2016 and current Italian legislation.

The Company undertakes to disclose and disseminate this Code of Ethics to all its stakeholders, requiring in particular its employees, suppliers and external collaborators to adhere to the principles contained herein.

The Society undertakes to sponsor only events that have cultural, sports or charitable value, including with the aim of enhancing initiatives in the area. Of any sponsorships and contributions, traceability is guaranteed.

The Company undertakes to grant donations exclusively to associations, foundations, public and nonprofit entities, which are duly established, in compliance with the requirements of accounting, civil and tax regulations and according to the principles of maximum fairness and transparency.

Of any donations, traceability is guaranteed.

The Company, in preparing the financial statements and all other corporate communications required by law, observes and requires its employees to:

comply with the relevant codified regulations and accounting standards:

• fairly and truthfully represent the financial position of the Company.

  In addition, the Company prohibits:

• making, outside the cases of legitimate reduction of share capital, including through simulated conduct, returns of contributions made by the shareholder or releasing the shareholder from the obligation to make them;
• resolving distributions of profits or advances on profits not actually earned or allocated to legal reserves or distributing unavailable reserves;
• fictitiously form or increase the capital of Companies, by allocating shares for an amount lower than their par value, to deliberate reciprocal subscription of shares, to significantly overvalue contributions of assets in kind or credits, or of the assets of Companies in case of transformation;
• carry out reductions of share capital, mergers or demergers in violation of legal provisions protecting creditors;
• determine, by simulated or fraudulent acts, fictitious majorities in the Company’s meetings.

Recipients are obliged to observe and comply with the principles of this Code and to conform to its rules of conduct.

Knowledge of and compliance with the prescriptions of the Code are a prerequisite for the establishment and maintenance of collaborative and correct relations with third parties, to whom the Company undertakes to disseminate any related information.

Violation of the prescriptions contained in this Code by suppliers, external collaborators, partners, procurers and consultants are considered a serious breach on their part and could constitute grounds for termination of the contractual relationship.