Table of Contents
THE VISION
beSharp is aware that the keys to a company’s success are primarily the competence of its people, the high quality of the service provided to its customers, and above all, the attention paid to the needs of the entire community.
The principles that have always inspired the modus operandi of this Company are gathered in this Code of Ethics and Conduct, as beSharp strongly believes that reliability is built daily by respecting the rules and valuing people. This Code of Ethics stands, therefore, as a distinctive and identifying element towards Customers, Suppliers, and third parties, the knowledge and sharing of which – required of all those who, in any capacity, operate within the Company or collaborate with it – constitute the foundation of our business as well as a fundamental step for the internalization and pursuit of our vision.
The main objectives that beSharp has set for itself are:
- to achieve excellence in its reference market through sustainable development, safeguarding the environment and the safety of the people involved, as well as implementing consistent and respectful behaviors;
- to achieve satisfaction and create widespread value for personnel, customers, and, more generally, for the community.
PURPOSE AND RECIPIENTS
This Code of Ethics (hereinafter, the “Code”) outlines the set of ethical and moral principles underlying the business activities of beSharp spa, as well as the lines of conduct adopted by the same both internally and externally in relations with institutions, suppliers, customers, business partners, political and trade union organizations, as well as with the media (“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.
It is necessary, first of all, to highlight how beSharp, considering fundamental the principle enshrined in Article 41 of the Italian Constitution, according to which private economic initiative “may not be carried out in conflict with social utility or in such a manner that could damage safety, liberty, and human dignity,” strongly believes that every activity must be carried out ethically.
This Code is binding for those who manage and work for beSharp, as well as for all those who operate and collaborate, permanently or temporarily, on behalf of the Company (“Recipients”).
We ask those who work with us to know the Code and respect it, and we ask the same commitment of suppliers and partners.
The Code will be widely disseminated within the internal governance structure, as well as communicated externally.
beSharp also undertakes to adopt any further tool that may be necessary in order to observe, disseminate, and apply the principles and provisions of the Code.
GENERAL PRINCIPLES
The conduct of the Recipients, whatever their corporate role, is based on the principles of legality, fairness, non-discrimination, loyalty, diligence, and confidentiality.
Legality
beSharp, in the exercise of its activities, operates in absolute compliance with the law and this Code. Therefore, all Recipients are required to observe all applicable regulations and keep up to date with legislative developments, also by taking advantage of any training opportunities offered by beSharp.
The Company believes that the transparency of financial statements and accounting is a fundamental element for the proper and transparent exercise of its business, as well as for the protection of its reputation.
Fairness
beSharp considers fairness and moral integrity unfailing 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 carrying out their activities, Recipients must not accept any consideration (by way of example but not limited to: gifts, favors, or benefits of any kind) in order to improperly grant advantages to third parties.
Similarly, Recipients must not make gifts of money or goods to third parties or otherwise offer illicit benefits or favors of any kind (except for items of modest value or authorized commercial courtesy gifts from the Company) in the exercise of the activity they perform for the benefit of beSharp.
The intrinsic belief of acting in the interest of the Company does not constitute a justification for the Recipients, who have the obligation to strictly observe the rules and principles of this Code.
Non-Discrimination
beSharp, in its relations with Stakeholders – particularly in the areas of: personnel selection and management, work organization, selection and management of suppliers, as well as in relations with Bodies and Institutions – repudiates any discrimination based on, by way of example but not limited to, age, gender, race, sexual orientation, health status, political and trade union opinions, religious beliefs, culture, and nationality of its interlocutors.
At the same time, beSharp fosters integration, promoting intercultural dialogue and the protection of the rights of minorities and vulnerable subjects. We do not tolerate harassment of any kind: physical, verbal, written, or digital, nor any form of mobbing or behavior that humiliates or degrades a person, in relations among personnel as well as with customers, suppliers, and anyone else we encounter while working.
Loyalty
beSharp and the Recipients undertake, within their reference market, to act fairly and in compliance with national and EU regulations, thus establishing a virtuous competitive model that constitutes a healthy incentive for innovation and development processes and protects the interests of consumers and the community.
Diligence
The relationship between beSharp and its personnel is based on mutual trust: the latter are, therefore, required to work to promote the company’s interests, always in compliance with the values set out in this Code.
Recipients must refrain from any activity that could constitute 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 direct supervisor without delay so that beSharp can evaluate and, if necessary, authorize the potentially conflicting activity.
In cases of violation, the Company will adopt any suitable measure to end the conflict of interest, reserving the right to act for its own protection in the manner it deems most appropriate.
Confidentiality
beSharp undertakes to guarantee the protection and confidentiality of the personal data of Recipients and Stakeholders, of which it becomes aware for work reasons or in any other capacity, in compliance with all applicable personal data protection regulations.
Recipients are therefore expressly forbidden to use confidential information, learned by reason of their work activity, for purposes extraneous to the exercise of said activity; they must always act in compliance with the confidentiality obligations assumed by beSharp towards all Stakeholders.
In particular, Recipients are held to the utmost confidentiality regarding documents capable of revealing know-how, technical information, commercial information, and corporate operations, of both beSharp and Stakeholders.
RELATIONS WITH PERSONNEL
Personnel selection
Personnel evaluation and selection are carried out according to the principles of fairness and transparency, respecting equal opportunities and trying to combine beSharp’s needs regarding the professional profiles sought with the expectations and ambitions of the candidates. beSharp is committed to taking every useful initiative to avoid any form of favoritism in the personnel selection process by using objective and meritocratic criteria, in respect of the candidates as well as in the interest of the good performance of the company.
Hired personnel, also through the implementation of this Code, receive clear, precise, and correct information about the roles, responsibilities, rights, and duties of the parties.
Personnel management
beSharp protects and values the people who, in any capacity, collaborate with it, committing to guarantee the necessary conditions for their professional growth. In particular, it incentivizes training – by organizing courses and workshops that deal with technical and non-technical topics, and by financing the achievement of professional certifications that will forever be a personal asset – and promotes any other initiative aimed at pursuing these purposes.
beSharp facilitates the participation of Recipients in the life of the company, promoting moments of aggregation organized taking into consideration also the opinions and suggestions expressed by them through internal surveys.
Without prejudice to the utmost availability towards beSharp, no Recipient can be obliged to perform duties, services, or favors not owed under their employment contract and their role within the company.
beSharp is firmly committed to fighting episodes of mobbing, stalking, psychological violence, and any discriminatory behavior or behavior harmful to personal dignity inside or outside company premises.
Relations among people working at beSharp must always be based on the principles of loyalty, fairness, and mutual respect, in compliance with the values of civil coexistence and individual freedom.
WORK ENVIRONMENT
beSharp is committed to offering its personnel a healthy, collaborative, safe work environment respectful of their dignity, in which everyone feels free to bring their own value based on their skills and knowledge.
Workplace safety is ensured both by strictly observing the provisions of the relevant law and by actively promoting a culture of safety through specific training courses.
beSharp protects the health of the people who collaborate with it, also ensuring compliance with hygiene and health prevention regulations.
COMPANY MANAGEMENT
Compliance with internal procedures
beSharp believes that management efficiency and the culture of internal control – understood as the set of rules, procedures, and organizational structures aimed at enabling a sound and correct conduct of the company through an adequate process of identification, measurement, management, and monitoring of major risks – are indispensable elements for achieving objectives.
Recipients are required to strictly observe beSharp’s internal procedures and policies, must act according to their respective authorization profiles, and must keep all suitable documentation to track actions taken on behalf of the company.
Accounting management
In accounting management activities, Recipients are called upon to act in compliance with the principles of truthfulness, accuracy, and transparency, so that beSharp’s reputation is protected at every level, both internally and externally.
Compliance with these principles also allows beSharp to plan its operational strategies based on its real economic and financial situation.
All items recorded 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 income statement items based on valuations and estimates, the related recording must be inspired by criteria of reasonableness and prudence.
Protection of corporate assets
Recipients exercise their functions by seeking to rationalize and contain the use of company tools.
Recipients are required to correctly apply security provisions to protect devices and tools made available by beSharp from unauthorized access, which could seriously harm the Company’s assets and/or the fundamental rights and freedoms of the people who work with beSharp or the stakeholders of customers.
Communication
beSharp takes steps to provide Stakeholders with suitable communication and reporting tools, enabling them to interact with the company by forwarding requests, asking for clarifications, making complaints, or reporting violations of this Code.
beSharp promotes effective corporate communication and maintains contacts with civil society to incorporate the requests, necessities, and needs of the community and to spread its values and mission.
The information disseminated to Stakeholders is precise and exhaustive so as to allow them to make correct and informed decisions.
beSharp’s advertising promotion respects ethical values, protecting minors and repudiating any type of vulgar or offensive message.
EXTERNAL RELATIONS
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 laws and according to the highest moral and professional standards.
Recipients, unless expressly authorized, may not relate in the name and on behalf of beSharp with Authorities and the Public Administration.
In relations with Public Officials, Persons in Charge of 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 and of the Integrated Management System, as well as, more generally, the provisions of the directives issued by beSharp management.
If a person exercising a public function asks for, or hints at expecting, money, gifts, hiring, discounts, or other advantages in order to do or not to do something, Recipients shall not comply with the request, even when a refusal risks costing us time, an authorization, or a business opportunity. Yielding so as not to lose an opportunity remains a violation of the Code. The request must be reported immediately to Management or reported via the dedicated platform.
Relations with the Judicial Authority
When the Judicial Authority, or whoever assists it, requests information, documents, or clarifications, beSharp cooperates and responds comprehensively and truthfully, without hiding anything and without embellishing anything.
Anyone called upon to make statements in a proceeding shall do so freely and truthfully. No one in beSharp may ask a person to remain silent, to misremember, or to tell a falsehood, nor suggest it, nor imply it, nor promise anything in exchange for silence or an accommodating statement.
Relations with political and trade union organizations
beSharp neither favors nor discriminates against any political or trade union organization and refrains from providing any undue contribution in any form to parties, trade unions, or other social groups, except for specific exceptions and in any case always within the limits of what is permitted by current regulations.
Recipients are required to refrain from any direct, indirect, or boasted pressure on political figures or trade union representatives.
Relations with customers and suppliers
Recipients relate to third parties with courtesy, competence, and professionalism, in the belief 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 customers or suppliers to rely on untrue facts or circumstances.
Recipients are also required to constantly commit to offering beSharp customers punctual and high-quality services, trying to limit any form of disservice or delay so as to maximize customer satisfaction.
Relations with suppliers are based on principles of loyalty, fairness, and transparency.
The selection of suppliers is carried out based on objective criteria of cost-effectiveness, opportunity, efficiency, and sustainability.
It is expressly forbidden to select suppliers on purely subjective and personal bases or, in any case, based on interests conflicting with those of the company.
Recipients must put in place every possible check to ensure that suppliers and customers are also capable of complying with the fundamental ethical principles set out in this Code.
Relations with schools and research institutions
beSharp considers it fundamental, for the social, economic, and technological development of the territory in which it operates, to support schools and research. For this reason, it contributes directly by providing its services free of charge. It also encourages – in primary and secondary schools – the approach to programming and hosts high school students within the framework of the school-work alternation project.
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 required 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 every necessary measure to put an end to violations, being able to resort to any disciplinary action in compliance with the law and workers’ rights, including trade union rights.
DISCIPLINARY SYSTEM GUIDELINES
The internal control system is oriented towards 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 provisions and procedures.
The violation of the principles established in the Code and in the procedures indicated in the internal controls compromises the relationship of trust between beSharp and the subjects, Recipients, or Stakeholders who have committed it.
Such violations will therefore be immediately pursued by beSharp rigorously and promptly, through the adoption of adequate and proportionate disciplinary measures. The effects of violations of the Code of Ethics and the Management System must be taken into consideration by all those who, in any capacity, maintain relations with beSharp.
Depending on the severity of the conduct carried out by the subject involved in one of the illicit activities provided for in this Code, beSharp will promptly take the measures it deems most appropriate, regardless of any potential exercise of action by the judicial authority.
The identification and application of sanctions will take place in compliance with the general principles of proportionality and adequacy, as described in the specific procedures.
This Code is approved by the Board of Directors of beSharp spa, updated as of July 24, 2026, and is published on the besharp.it website.