Code of Ethics – Brianzatende s.r.l.

Introduction

This Code of Ethics expresses the ethical principles and values that Brianzatende adheres to in the conduct of its activities. All employees, collaborators, managers, suppliers, and partners are required to comply with the rules contained in this document.

It is important to clearly and precisely define the set of values that the Company as a whole recognizes, accepts, and shares, as well as the responsibilities it assumes both internally and externally. Compliance with this Code by employees and collaborators is essential for the proper functioning, integrity, and reputation of the company, which are decisive assets for the success of the business.

The Company undertakes to disseminate the contents of this Code in the most appropriate manner; each employee/collaborator is required to know it, respect it, and contribute to its implementation.

General Principles

• All activities must be carried out with honesty and integrity, respecting the interests of customers, employees, shareholders, commercial and financial partners.
• All actions, operations, and transactions carried out by Brianzatende must be inspired by the highest standards of fairness in management and transparency of information, and by formal and substantive legality.
• Employees/collaborators must comply with current laws and regulations, guiding their actions and behavior according to the principles, objectives, and commitments outlined in the Code.
• Relationships among employees/collaborators at all levels must be based on fairness, loyalty, and mutual respect. Brianzatende is committed to encouraging and facilitating constructive dialogue on the commitments, responsibilities, and behavioral guidelines contained in the Code.
• In light of the above and what will be further specified, Management, including through the HR Department, may sanction behaviors that clearly conflict with the provisions of this Code.

Personnel Policies

• It is primarily the responsibility of Managers and Supervisors to give substance to the values and principles contained in the Code, fulfill responsibilities internally and externally, and strengthen trust, cohesion, respect, and corporate spirit.
• Managers and Supervisors must serve as role models and align their conduct with the principles set out in this Code, demanding compliance from employees and collaborators. Each Manager and Supervisor is accountable for their team and must monitor to prevent violations of the Code. Any irregularities must be reported to Management/HR for appropriate action.
• Managers and Supervisors are required to implement projects and actions that enhance the managerial and technological values of the company, and promote well-being for employees and the community.
• Each employee/collaborator must recognize and respect the personal dignity, privacy, and personality rights of every individual. Discrimination, harassment, and offensive behavior of a sexual or personal nature are not tolerated.
• Passion and professionalism are key values for achieving the company’s goals. For this reason, Brianzatende follows a merit-based and equal opportunity policy.
• All company activities must be carried out with commitment and ethical rigor. Each employee must contribute appropriately to their responsibilities and act to protect Brianzatende’s image.
• Personnel selection and hiring are conducted based on the alignment of individual and professional qualities with the provisions of this Code.
• Management, executives, employees, and collaborators work synergistically to achieve positive common results and strive to create a serene, stimulating, and rewarding work environment.
• Employees/collaborators are not permitted to engage in side activities that conflict with their specific obligations to Brianzatende.
• Each employee/collaborator is responsible for safeguarding and preserving the assets and resources entrusted to them by Brianzatende for the performance of their duties.
• No employee may misuse Brianzatende’s assets and resources or allow others to do so.

External Relations

• Brianzatende maintains a relationship of trust with each employee/collaborator.
• Employees/collaborators must avoid situations and activities that may create a conflict with the Company’s interests or interfere with their ability to make impartial decisions in the best interest of the business.
• Any situation that may constitute or lead to a conflict of interest must be promptly reported to their Supervisor.
• The Company is committed to combating all forms of corruption, direct and indirect, public or private, in all areas of its activities, adopting a zero-tolerance approach.
• In the performance of their duties, employees and collaborators are required to comply with the Anti-Corruption Policy. Customers are an integral part of Brianzatende’s corporate assets.
• Brianzatende maintains relationships with customers and suppliers who respect fundamental principles and, considering their legal, social, economic, and cultural context, the rules of this Code.
• Employees/collaborators must carry out their activities toward customers with competence, precision, dedication, efficiency, honesty, loyalty, availability, courtesy, and transparency.
• Regarding suppliers, Brianzatende pursues a fair and impartial selection policy.
• This section reiterates the points already specified above, particularly those related to conflicts of interest and donations, benefits, or other advantages.

Corporate Policies

• The Company complies with the laws in force in the reference country and also with those introduced by international sources, regarding: promotion and support of human rights, prohibition of forced labor, prohibition of child labor, compliance with working hours, prohibition of discrimination, freedom of association.
• Environmental protection and conservation of natural resources are objectives actively pursued by Brianzatende, and each employee/collaborator must contribute to achieving optimal results in this area.
• The health and safety of employees/collaborators is a priority for Brianzatende. Compliance with applicable regulations and the upgrading of infrastructure and machinery are integral parts of the Company’s good management policy.

Confidential Information

• Information, knowledge, and data acquired or processed by employees/collaborators during their work or through specific activities belong to Brianzatende and may not be used, communicated, or disclosed without specific authorization from the Legal Representative.
• Confidential information includes all data, documents, reports, studies, drawings, photographs, and any other material related to the organization and company assets, production methods, commercial and financial operations, research and development activities, and legal and administrative proceedings involving the Company.
• Personal and third-party data processed by Brianzatende in the course of its activities must comply with privacy regulations.