Bawer SPA Code of Ethics

The Code of Ethics adopted by BAWER SpA is a set of principles and rules, compliance with which is of fundamental importance for the proper functioning and improvement of the Company’s reliability. It represents the “Charter of Fundamental Rights and Duties” through which the Company:

1. 1. clarifies its ethical and social responsibilities towards various internal and external stakeholders, such as: shareholders, employees, collaborators, suppliers, public bodies, customers, etc.;
2. seeks ways to balance and/or find equilibrium points between the multiple interests and legitimate expectations put forward by stakeholders.

PRINCIPLES

BAWER SpA believes that the ethical principles that govern the Western economic and industrial world must be respected by each of its members, be they managers, employees, collaborators, customers, suppliers, etc.
These principles are represented by the utmost respect for:
1. human dignity in all its forms;
2. the care and protection of the health and physical and moral integrity of its workers and collaborators;
3. fairness in commercial relationships with suppliers and customers;
4. transparency in relations with the Public Administration and/or supervisory and control bodies in all their forms of expression.

RULES AND STANDARDS OF CONDUCT

BAWER SpA is committed to guaranteeing:
1. IMPARTIALITY: Offer equal employment opportunities to all employees and collaborators based on professional qualifications and performance capabilities, without discrimination based on ethnicity, religion, opinion, nationality, gender, age, physical or social conditions.
2. WORK ENVIRONMENT: ensure that in internal and external working relationships, there is no sexual harassment or behavior or initiatives that create an intimidating, hostile, or isolating working environment for individuals or groups of workers, that negatively interfere with the performance of others’ work, or that hinder the employment and/or career prospects of others, for reasons of personal competitiveness alone.
3. DEVELOPMENT: develop the skills and abilities of each employee and collaborator through training and refresher courses;
4. VALUE OF RESOURCES: ensure fair treatment based on merit and competence criteria
5. PRIVACY: protect information relating to employees and collaborators generated or acquired within and outside the Company and take all necessary measures to prevent improper use of such information.
6. HEALTH AND SAFETY: promote and protect the health and safety of its employees and collaborators.

The Recipients undertake to:
1. RESPONSIBILITY: provide the contractual service, consistently with the assigned tasks, objectives and responsibilities, without delegating to other employees or collaborators the completion of activities or the adoption of decisions that are their responsibility.
2. DILIGENCE: If employed, respect working hours, except for justified reasons, and limit absences from the workplace to those strictly necessary; if employed, dedicate adequate resources, in terms of time and dedication, to assigned tasks in order to achieve the relevant objectives.
3. RESPECT: Adopt respectful and sensitive behavior towards others, avoiding working under the influence of alcohol, drugs or similar substances and avoiding consuming or supplying such substances for any reason during work.
4. COMPANY CLIMATE: contribute to the creation of a professional climate in which all colleagues feel positively involved in achieving company objectives.
5. HONESTY: Use the goods and resources made available in accordance with their intended corporate use and in a manner that safeguards their preservation and functionality, as each recipient is considered directly and personally responsible for the protection and preservation of the goods and resources entrusted to them for the performance of their duties. Therefore, they also undertake not to use office telephone lines for personal needs, except in emergencies, and comply with the provisions of the Company Regulations for the use of the computer system, the Internet, and e-mail. They also undertake not to use company vehicles for personal tasks and not to
transport people outside the Company, unless expressly authorized by the Company.
6. CONFIDENTIALITY: Use the utmost caution and care when using non-public information arising from the performance of your duties. The information
and any other material obtained in the performance of their duties are the property of the Company. Recipients undertake not to disclose, use, or communicate information and/or any other type of news, documents, data, etc., related to the acts and operations of each job or responsibility that are confidential without specific authorization. Anyone involved in a Report or in the investigation of an alleged violation under the Whistleblowing legislation is required to maintain the utmost confidentiality regarding the identity of the Reporter, the persons involved, and the contents of the report, except where permitted by law, as prescribed by the Company’s Whistleblowing Procedure.
Bawer.
7. CONFLICT OF INTEREST: avoid all situations and activities in which a conflict of interest may arise between personal economic activities and duties
covered in the Company or the interests of the Company itself. If, however, situations of conflict or potential conflict should occasionally arise, it is
Maximum communication and transparency is required towards the person in charge or the relevant function for any necessary measures.
8. GIFTS: Accept or offer, directly or indirectly, commercial courtesy, such as gifts, payments, and benefits, only when they cannot be interpreted as being intended to improperly acquire advantages for oneself or the Company. Any employee or collaborator who receives or offers gifts that cannot be ascribed to normal, proper courtesy must directly inform their manager or the appropriate function and refuse.
9. HEALTH AND SAFETY: participate in the process of risk prevention, environmental protection, and health and safety protection for oneself, colleagues, and third parties.
10. ADMINISTRATIVE RESPONSIBILITY: The transparency, accuracy, and completeness of financial statement information are of particular importance. In this regard, each employee is required to cooperate to ensure that operating events are correctly represented. The information included in periodic reports or in both general and analytical accounting must comply with the principles of transparency, correctness, completeness, and accuracy. Accounting records must be based on precise, comprehensive, and verifiable information. Each entry in the accounting books must reflect the nature of the transaction, represent its substance, and be based on adequate supporting documentation.
11. COMMUNICATION: Employees who are aware of or suspect any of the violations covered by the Whistleblowing regulations may report them according to the procedures described in the Company’s Whistleblowing Procedure. The Company will take appropriate disciplinary measures against anyone who engages in intimidating or discriminatory behavior or retaliatory conduct against anyone who provides information on violations or unlawful conduct pursuant to the aforementioned Whistleblowing Procedure.

Whistleblowing

1. The Company, in its effort to combat illegal activities and improve
constantly the corporate culture characterized by correct behaviors, has
adopted the Whistleblowing Procedure which describes the reporting methods
violations and/or illicit activities (so-called Whistleblowing) in compliance with current legislation and
works to provide whistleblowers in good faith with extensive protection and confidentiality.
2. The Company therefore:
• has implemented internal channels for reporting violations and/or illicit activities;
• has entrusted the management of reports to an autonomous, dedicated entity,
specifically trained and equipped with the necessary skills to follow up on the
reports received;
• maintains the strictest confidentiality regarding the reports received;
• prohibits any form of retaliation or discrimination against
reporting;
• guarantees the protection of the authors of the reports from any act of retaliation or
discrimination they may face for having made the report and
maintains confidentiality of identity, except as required by law;
• also protects facilitators, people linked to the whistleblower by a stable relationship
affective or kinship within the fourth degree, operating in the same context
work, the work colleagues of the Reporter; the Entities owned by the Reporter or which
operate in the same work context as him; the anonymous whistleblower, if subsequently
identified and subject to retaliation;
• apply appropriate sanctions against those who violate the protection measures of the
reporting person, of anyone who also violates the confidentiality obligation relating to the person involved and/or
mentioned in the report;
• applies disciplinary and/or sanctioning measures, or legal action
in the case of reports that prove to be unfounded or opportunistic, whether they are
coming from internal or external channels. The Reporter who made the Report
in good faith cannot be sanctioned.
EXTERNAL RELATIONS
1. CUSTOMERS: Relationships with Customers must aim for excellence in the product, in the
service and quality; must be inspired by principles of transparency and fairness and
good faith; they must respect the rules of the market and competition.
2. SUPPLIERS: The selection of Suppliers and the negotiation must take place in
transparent manner, in compliance with the regulations applied in the different countries and must
respect rigorous parameters of competitiveness, objectivity, correctness, price and quality
of good and service.
3. PUBLIC ADMINISTRATION: Relations with the Public Administration
can be managed exclusively by company functions specifically designated for this purpose
delegated and authorized. Such relationships must:
a. be based on transparency, fairness, independence and impartiality;
b. comply with the regulations applicable in the various countries;
c. ensure certainty of the communication methods in order to avoid
incorrect interpretations in the reconstruction of the procedures followed.