Company Code of Ethics

Beca Group Srl, implements this Company Code of Ethics (also referred to as “Code”) which contains the main principles of correctness, transparency, lawfulness and moral integrity. These principles represent an essential condition for the activities of Beca Group Srl and to achieve the production, economic and social aims and objectives of the company.
Specifically, this Company Code of Ethics sets out:

Conduct rules, in relations with external workers and operators, collaborators, the marketplace and the environment, to which the company provides information about its activities (internal or external), requiring compliance by all stakeholders (partners, employees and collaborators, and – insofar as within their competence – external operators);
Organisation and management rules for professional activities, for the purpose of obtaining an effective and efficient system that can plan, execute and check activities, able to guarantee constant compliance with the rules of conduct, and preventing breaches by any subject operating on behalf of the Company.

This document is not intended as a means to solve disputes of any nature, but rather it is a point of reference for each operator and a reminder to abide by basic ethical principles in business and work every day.

1 Circulation and updates

This Code has been circulated within Beca Group Srl and is available to any subject dealing with the Company.
Each partner, employee and collaborator of Beca Group Srl is obliged to know, abide by and ensure compliance with the regulations in this Code. By using suitable tools, Beca Group Srl is able to check compliance with the Code and, if necessary, intervene with corrective actions. The Company Code of Ethics has been drawn up based on Guidelines concerning “Company Administrative Liability” and can be amended and/or integrated at any time, should the need arise.

2 Relations with external operators

2.1 Competition
The company policy of Beca Group Srl is based on the principle of free and fair competition. All actions brought into play to perform professional activities are aimed at obtaining competitive results that reward the efficiency, skills and experience of resources. Beca Group Srl, as represented by its partners, employees and collaborators must conduct itself correctly in company business, with specific reference to relations with external interlocutors, whether private or public operators. Any action that may affect fair competition or which is against company policy is prohibited to all subjects acting on behalf of Beca Group Srl. Moreover, the pursuit of company interests does not justify conduct (by partners, employees or collaborators) that does not comply with the rules in this Code or respect current regulations and standards. In all external communications, information concerning the Company and its activities must be true, correct and verifiable.

2.2 Relations

2.2.1 External contractors.
Relations and relationships between the Company and any public or private contractor are based on the principles of correctness, transparency and verifiable. Specifically, insofar as relations with Public Administration are concerned, the Company proposes and shares compliance with the rules set down by the code of conduct for public employees, while as far as regards relations with client Companies, Beca Group Srl conforms to the code of conduct for these companies . In general, forms of gift that may appear to be in excess of normal business or courtesy practices and in any case, which are directed at obtaining favourable treatment in business conduct, are not accepted. With regard to representatives or employees of public or private companies, it is prohibited to seek or establish personal relationships of favour, influence or interference that may, directly or indirectly, affect the outcome of the relationship. Offers of goods or other utilities to representatives, officers or employees of public or private companies, even through third persons, are also prohibited, unless these are gifts of small value, compliant with custom and provided that they cannot be understood as means for obtaining undue favours. Beca Group Srl does not make donations or offer advantages and/or benefits to political parties or trade union organisations (or to their representatives) unless compliant with the general rules of transparency and in any case, in line with the relative legislation.

2.2.2 Customers and Contractors
The policy of Beca Group Srl is based on excellent quality and services, which translates as having the complete satisfaction of customers and other recipients of the business activities, according to the principles principles of expertise, diligence, professionalism, correctness and transparency. In its relations with customers, Beca Group Srl guarantees correctness and clarity in its business dealings and in acceptance of contractual constraints as well as in the faithful and diligent performance of contracts. When taking part in bids for tender and in the scope of private business dealings, Beca Group Srl carefully assesses the adequacy and feasibility of the services required, placing particular focus on the technical and economic factors and identifying, where possible, any potential anomalies. All offers are made in complete compliance with quality standards, remuneration for employees and current safety and environmental protection measures. Beca Group Srl does not resort to litigation except in specific cases in which its lawful claims are not satisfied by the other party. As part of any negotiation, Beca Group Srl avoids those situations in which the persons involved have or may potentially appear to have conflicting interests.

2.2.3 Suppliers
Relations between suppliers and Beca Group Srl (including specialist consultancy services, financial contracts, etc.) are regulated by this Code. Beca Group Srl uses the services of suppliers and subcontractors who work in compliance with current laws and with the regulations set down in this Code. Supplier selection and decisions concerning conditions of purchase are based on objective assessments of the supplier’s ability to supply and guarantee in good time, services of a level suitable for the Company as well as the quality and prices of the services required. Under no circumstances will a supplier be preferred over another based on personal relationships, favouritism or different advantages to those inherent to the exclusive interest and benefit of the Company.

2.3 Environment
In consideration of the rights of future generations, the environment is a primary asset that Beca Group Srl undertakes to protect.
Beca Group Srl therefore undertakes to improve the impact of its activities on the environment and the countryside, as well as to prevent risks to the population and the environment, not only through compliance with current regulations. Beca Group Srl undertakes to circulate and consolidate among partners, collaborators, subcontractors and clients, a culture of environmental protection and prevention of pollution, raising awareness of risks and promoting responsible behaviour on the part of all stakeholders.

3 Relations with collaborators

3.1 Work

Human resources are the main factor in the success of any business. Beca Group Srl promotes an environment of loyalty and trust between employer, employees and collaborators. Employees are managed with the utmost respect for the contract conditions of their sector, tax regulations, and national insurance payments. Persons who believe themselves to have been the subject of harassment or discrimination can inform the Partners of the Company of this and the actual breach of this Code will be assessed. Differences are not considered discrimination if they are justifiable based on objective criteria. Beca Group Srl promotes continued improvement in the professional skills of its employees and collaborators, also through its training programmes. Moreover, within its own possibilities, Beca Group Srl undertakes to ensure all partners, employees and collaborators, as well as staff from other companies or professional figures working jointly with the company or coordinated with same, even temporarily, will comply with all current laws and regulations, as well as with the organisational rules and procedures in place.

3.2 Health and Safety
Beca Group Srl undertakes to put in place working conditions that safeguard the physical and mental health of its workers and, respect for their moral liability, by avoiding discrimination, unlawful conditioning and undue discomfort. The Company carries out its activities in technical, organisational and economic conditions that allow suitable accident prevention levels to be guaranteed and a safe, healthy working environment. Beca Group Srl circulates a culture of safety within the company, developing risk awareness and promoting responsible conduct and prevention activities with all partners, employees and collaborators.

4 Implementation Methods

4.1 Prevention
In compliance with current regulations and with an eye to planning and managing company activities to achieve efficiency, correctness, transparency and quality services, Beca Group Srl uses organisational and management methods to prevent unlawful conduct or conduct that is in any case contrary to the directions of this Code, by any person acting on behalf of same.