Table of Contents
VISION
beSharp is aware that the keys to a company’s success are primarily the competence of its collaborators, the high quality of the service provided to its clients, and, above all, the attention dedicated to the needs of the community as a whole.
The principles that have always inspired this Company’s modus operandi are gathered in this Code of Ethical Conduct, as beSharp strongly believes that
reliability is built daily by respecting regulations and valuing people. This Code of Ethics serves, therefore, as a distinctive and identifying element toward Clients, Suppliers, and third parties. Awareness and sharing of this Code — required of all those who, in any capacity, operate within the Company or collaborate with it — form the foundation of our business as well as a fundamental step toward internalizing and pursuing our vision. The main objectives that beSharp has set for itself are:
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to achieve excellence in its reference market through sustainable development, safeguarding the environment and the safety of the people involved, and by
implementing behaviors consistent with and respectful of Social Ethics;
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to achieve satisfaction and create shared value for the Employee, the Client, and, more generally, the Community.
PURPOSE AND RECIPIENTS
This Code of Ethics (hereinafter, the “Code“) outlines the set of ethical and moral principles underlying the activities of beSharp spa (hereinafter, “beSharp” or the “Company”) as well as the guidelines of conduct adopted by the Company both internally (in relations with its collaborators) and externally in relations with institutions, suppliers, clients, commercial partners, political and trade union organizations, and media outlets (hereinafter, the “Stakeholders”).
Compliance with these principles is essential to pursue beSharp’s corporate mission and to guarantee its image and reputation within the socio-economic context in which it operates.
First and foremost, it is necessary to highlight that beSharp, considering fundamental the principle enshrined in Article 41 of the Italian Constitution, according to which private economic initiative “cannot be carried out in conflict with social utility or in such a manner as to cause damage to safety, freedom, or human dignity,” strongly believes that every activity must be conducted ethically.
This Code is binding for beSharp’s directors and employees, as well as for all those who operate and collaborate, permanently or temporarily, on behalf of the Company (hereinafter, the “Recipients”).
The Code will be widely disseminated within the internal governance structure, as well as communicated externally.
beSharp also undertakes to adopt any further measures that may be necessary to observe, disseminate, and apply the principles and provisions of the Code.
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GENERAL PRINCIPLES
The conduct of the Recipients, regardless of their corporate role, is guided by the principles of legality, fairness, non-discrimination, loyalty, diligence, and confidentiality.
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Legality
In the performance of its activities, beSharp operates in absolute compliance with the law and this Code.
Therefore, all Recipients are required to observe all applicable regulations and to keep themselves updated on legislative developments, also by taking advantage of any training opportunities offered by beSharp.
The Company believes that financial and accounting transparency constitutes a fundamental element for the proper and transparent conduct of its business, as well as for the protection of its reputation.
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Fairness
beSharp considers fairness and moral integrity to be indispensable duties for all Recipients. They are, therefore, required not to establish any privileged relationship with third parties arising from external solicitations aimed at obtaining improper advantages.
In the performance of their activities, Recipients must not accept any counter-performance (including, but not limited to: donations, favors, or utilities of any kind) intended to improperly grant advantages to third parties.
Similarly, Recipients must not make monetary donations or gifts of goods to third parties, or otherwise offer unlawful utilities or favors of any kind (except for items of modest value or commercial courtesy gifts authorized by the Company) in the course of the activities performed for the benefit of beSharp.
The intrinsic conviction of acting in the interest of the Company does not constitute a justification for Recipients, who are under the obligation to strictly observe the rules and principles of this Code.
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Non-Discrimination
In its relations with Stakeholders — particularly in the areas of personnel selection and management, work organization, selection and management of suppliers, as well as relations with Entities and Institutions — beSharp rejects any discrimination based on, but not limited to, age, sex, race, sexual orientation, health status, political and trade union opinions, religious belief, culture, and nationality of its interlocutors.
At the same time, beSharp fosters integration, promoting intercultural dialogue, the protection of minority rights, and vulnerable individuals.
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Loyalty
beSharp and the Recipients undertake to act fairly and in compliance with national and EU regulations within their reference market, thereby establishing a virtuous competitive model that constitutes a healthy incentive for innovation and development processes and protects the interests of consumers and the community.
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Diligence
The relationship between beSharp and its employees and collaborators is based on mutual trust: the latter are, therefore, required to operate to promote the company’s interests, always in compliance with the values set forth in this Code.
Recipients must refrain from any activity that may configure a conflict of interest with beSharp, avoiding the pursuit of personal interests in conflict with the legitimate interests of the Company.
Should the possibility of a conflict of interest arise, Recipients are required to contact their hierarchical superior without delay, so that beSharp can evaluate and, if appropriate, authorize the potentially conflicting activity.
In cases of violation, the Company will adopt all appropriate measures to terminate the conflict of interest, reserving the right to act for its own protection in the manner it deems most appropriate.
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Confidentiality
beSharp undertakes to guarantee the protection and confidentiality of the personal data of Recipients and Stakeholders that it becomes aware of for work-related reasons or in any other capacity, in compliance with all applicable data protection regulations.
Therefore, Recipients are expressly forbidden from using confidential information acquired by reason of their work activities for purposes unrelated to the performance of such activities; they must always act in compliance with the confidentiality obligations undertaken by beSharp toward all Stakeholders.
In particular, Recipients are required to maintain the utmost confidentiality regarding documents capable of revealing know-how, technical information, commercial information, and corporate operations, belonging both to beSharp and to Stakeholders.
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RELATIONS WITH EMPLOYEES AND COLLABORATORS
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Personnel selection
The evaluation and selection of personnel are carried out in accordance with the principles of fairness and transparency, respecting equal opportunities and seeking to combine beSharp’s professional profile requirements with the candidates’ expectations and ambitions. beSharp undertakes to adopt any useful initiative to avoid any form of favoritism in the personnel selection process by using objective and merit-based criteria, out of respect for the candidates and in the interest of the smooth running of the company.
Hired personnel, also through the implementation of this Code, receive clear, precise, and correct information regarding the roles, responsibilities, rights, and duties of the parties.
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Personnel management
beSharp protects and values the people who collaborate with it in any capacity, committing to guarantee the necessary conditions for their professional growth. In particular, it encourages training — by organizing courses and workshops covering both technical and non-technical topics, and by financing the achievement of professional certifications that will remain a permanent asset for its collaborators — and promotes any other initiative aimed at pursuing these goals.
beSharp facilitates the participation of Recipients in the company’s life, fostering social gatherings organized by also taking into account the opinions and suggestions expressed by them through internal surveys.
Without prejudice to maximum availability toward beSharp, no Recipient can be forced to perform tasks, duties, or favors not owed under their employment contract and their role within the company.
beSharp is firmly committed to countering episodes of mobbing, stalking, psychological violence, and any discriminatory behavior or behavior harmful to personal dignity inside or outside company premises.
Relations between employees must always be based on the principles of loyalty, fairness, and mutual respect, in compliance with the values of civil coexistence and individual freedom.
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WORK ENVIRONMENT
beSharp is committed to offering its personnel a healthy, collaborative, safe work environment that respects their dignity, within which everyone feels free to contribute their own value based on their skills and knowledge.
Workplace safety is ensured both by strictly observing the relevant legal provisions and by actively promoting a culture of safety through specific training courses.
beSharp protects the health of its collaborators, also guaranteeing compliance with hygiene and health prevention regulations.
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BUSINESS MANAGEMENT
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Compliance with internal procedures
beSharp believes that management efficiency and an internal control culture — understood as the set of rules, procedures, and organizational structures aimed at ensuring sound and correct business management through an adequate process of identification, measurement, management, and monitoring of main risks — are indispensable elements for achieving its objectives.
Recipients are required to strictly observe beSharp’s internal procedures and policies, must act according to their respective authorization profiles, and must retain all appropriate documentation to keep track of actions taken on behalf of the company.
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Accounting management
In accounting management activities, Recipients are called upon to act in compliance with the principles of truthfulness, accuracy, and transparency, to protect beSharp’s reputation at every level, both internally and externally.
Compliance with these principles also allows beSharp to plan its operational strategies based on its actual economic and financial position.
All items reported in the accounts must, therefore, be supported by complete, clear, and valid documentation, avoiding any form of omission, falsification, and/or irregularity.
In the case of balance sheet or economic items based on evaluations and estimates, the relevant recording must be guided by criteria of reasonableness and prudence.
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Protection of corporate assets
Recipients exercise their functions trying to rationalize and limit the use of company tools.
Recipients are required to properly apply security provisions to protect the hardware devices provided by beSharp from unauthorized access, which could seriously prejudice the right to personal data protection of beSharp’s employees, collaborators, and clients.
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Communication
beSharp provides appropriate communication tools to Stakeholders, enabling them to interact with the company by submitting requests, asking for clarifications, or making complaints.
beSharp promotes effective corporate communication and maintains contact with civil society in order to understand the demands, requirements, and needs of the community and to spread its values and mission.
Information disseminated to Stakeholders is precise and comprehensive so as to allow them to make correct and informed decisions.
beSharp’s advertising and promotion respect ethical values, protecting minors and rejecting any type of vulgar or offensive message.
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EXTERNAL RELATIONS
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Relations with Authorities and Public Administrations
Relations with Authorities and the Public Administration are based on the utmost clarity, transparency, and collaboration, in full compliance with applicable regulations and according to the highest moral and professional standards.
Except with express authorization, Recipients may not interact in the name and on behalf of beSharp with Authorities and the Public Administration.
In relations with Public Officials, Persons Chargeable with a Public Service, and the Public Administration in general, authorized Recipients must adhere to the highest levels of fairness and integrity, refraining from any form of pressure, explicit or veiled, aimed at obtaining any undue advantage for themselves or for beSharp.
In this regard, authorized Recipients will be required to strictly observe the provisions of this Code, as well as, more generally, the directives issued by beSharp’s management.
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Relations with political and trade union organizations
beSharp does not favor or discriminate against any political or trade union organization and refrains from providing any undue contribution in any form to parties, trade unions, or other social associations, subject to specific exceptions and in any case always within the limits permitted by current laws.
Recipients are required to refrain from any direct, indirect, or claimed pressure on political figures or trade union representatives.
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Relations with clients and suppliers
Recipients interact with third parties with courtesy, competence, and professionalism, in the conviction that the protection of beSharp’s image and reputation and, consequently, the achievement of corporate objectives also depend on their behavior.
In particular, Recipients must refrain from any form of unfair or deceptive behavior that could induce clients or suppliers to rely on untrue facts or circumstances.
Recipients are also required to constantly commit to offering beSharp’s clients timely and high-quality services, trying to limit any form of service disruption or delay so as to maximize customer satisfaction.
Relations with suppliers are based on the principles of loyalty, fairness, and transparency.
The choice of suppliers is made on the basis of objective criteria of cost-effectiveness, opportunity, efficiency, and sustainability.
The choice of suppliers on a merely subjective and personal basis or, in any case, made on the basis of interests conflicting with those of the company is expressly prohibited.
Recipients must implement all possible controls so that suppliers and clients are also able to respect the fundamental ethical principles set forth in this Code.
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Relations with schools and research
beSharp considers supporting schools and research to be fundamental for the social, economic, and technological development of the territory in which it operates. For this reason, it contributes directly by providing financial aid or performing its services free of charge. It also encourages — in primary schools, through donations — the introduction to programming and hosts high school students within the framework of the school-work alternation project (Alternanza Scuola-Lavoro).
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INTERNAL CONTROL SYSTEM
Compliance with the provisions of this Code is entrusted to the responsible, aware, and careful supervision of each of the Recipients, within their respective roles and functions. All Recipients are invited to report to their direct superiors any facts and circumstances potentially in conflict with the principles and provisions of this Code.
beSharp’s management and the bodies appointed for this purpose adopt all necessary measures to terminate violations, being able to resort to any disciplinary measure in compliance with the law and workers’ rights, including trade union rights.
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DISCIPLINARY SYSTEM GUIDELINES
The internal control system is oriented toward the adoption of tools and methodologies aimed at countering potential corporate risks, in order to guarantee compliance not only with laws but also with internal regulations and procedures.
The violation of the principles set forth in the Code and in the procedures indicated in the internal controls compromises the trust relationship between beSharp and the subjects, Recipients or Stakeholders, who implemented it.
Such violations will therefore be immediately prosecuted by beSharp in a rigorous and timely manner, through the adoption of appropriate and proportionate disciplinary measures. The effects of violations of the Code of Ethics and internal protocols must be taken into consideration by all those who, in any capacity, maintain relations with beSharp.
Depending on the seriousness of the conduct implemented by the individual involved in one of the illicit activities provided for by this Code, beSharp will proceed without delay to take the measures it deems most appropriate, regardless of any criminal prosecution by the judicial authority.
Without prejudice to the foregoing, conduct in violation of the Code of Ethics constitutes:
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a serious breach of contract for employees (workers, supervisors, and executives), with sanctions, commensurate with the severity, provided for by the applicable National Collective Labour Agreement – CCNL (verbal warning, written warning, fine not exceeding three hours’ pay, suspension from work and pay up to a maximum of three working days, dismissal for just cause or justified objective reason);
in the event of pending criminal proceedings or execution of a measure restrictive of personal liberty taken against the employee, before adopting the disciplinary measure, the sanction of suspension from service and pay may be adopted, for the duration corresponding to the outcome of the criminal action or until the end of the duration of the restrictive measure;
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just cause for revocation of the mandate of the directors;
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grounds for immediate termination of the contract, in the most serious cases, for external and coordinated collaborators (collaboratori parasubordinati);
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grounds for immediate termination of the contract, in the most serious cases, for suppliers, contractors, and subcontractors.
The identification and application of sanctions will take place in compliance with the general principles of proportionality and adequacy.
In the hypotheses indicated above, beSharp also reserves the right to take all actions it deems appropriate to obtain compensation for the damage suffered as a consequence of the conduct carried out in violation of the Code of Ethics.
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