Code of Ethics

Table of Contents

1. The Mission
2. The values
3. The principles of conduct
4. Internal control system
5. Stakeholders
6. Compliance with the Code

1. The Mission

The growth over the years has led the company to have an international dimension.
Our competitive strength is based on the professional skills of human resources, on technical capacity, on quality and constant attention to the needs of the customers. Factors that allow us to offer and market high quality services and to operate successfully in different markets at the international level.

The attitude of innovation and the ability to anticipate changes in the market lead us to continuous improvement in terms of quality, through the development of new solutions in the field of shipping and inspections.
Our conduct is inspired by a Code of Ethics which are called upon to apply consistently and responsibly all those who have relations with the Company all over the world. The excellence of BASE S.p.A. recognized internationally, is a systematic and prioritized commitment by management.

Our way of doing business seeks the best balance between personal responsibility and teamwork, centrality in the definition of strategic guidelines and decentralization of operational responsibilities. Our continued growth is supported by adequate creation general value, as well as respecting the interests of all those who interact with the company.

2. The values

FAIRNESS AND PROPERTY

Displaying fairness and correctness in doing one’s job both in dealings inside and outside the company.

TRANSPARENCY
Giving a clear, accurate, and timely report of economic/financial results within the Company and outside of it. Encouraging debate, to the extent of voicing disagreement with decisions by your superiors where there is an arguably better alternative. Being open to different views and encouraging change. Exchanging information across all levels in the organization.

SUSTAINABLE GROWTH
Working to ensure long-term responsible growth in full awareness of the inter-dependence of the economic, social, and environmental spheres, and being mindful of the effects a decision in one such sphere has on the others. Seeking to be a leader in the developments of service, ahead of market demand, in the knowledge of the benefits that today’s achievements will bring to tomorrow’s world. Linking together value creation, social progress, concern for stakeholder.

CUSTOMER FOCUS
Understanding the market in which the BASE S.p.A. operates and considering the impact on clients of all your actions and conduct. Turning any opportunity that arises in your work to the advantage of customers, anticipating their needs.

RESPONSIBILITY AND STRIVING AFTER RESULTS
Striving determinedly after results by becoming personally involved in forming plans, in developing them, and in generating concrete results.

PROFESSIONAL EXCELLENCE
Possessing technical know-how and applying the leverage it provides to become a front runner. Doing your job methodically and with relish while keeping to the rules.

INNOVATION
Being the first to come up with radical product/service solutions that can be implemented. Pursuing excellence and never accepting current standards as good enough. Constantly looking out for opportunities to upgrade existing processes and systems.

QUALITY AND PERFORMANCE
Ensuring the maximum quality of products as well as the excellence of production systems and processes. Maintaining an unflagging commitment to performance as a way of meeting customer expectations in terms of safety and service delivery.

INTEGRATION
Appreciating how a given action fits into the wider scheme of events. Co-operating across and within functions and geographical boundaries to achieve common goals. Raising efficiency and facilitating change while ensuring that duplication of effort is kept to a minimum.

SPEED
Sensing the urgency of delivering solutions that address stakeholders requirements, through early recognition of them. Reacting quickly to development needs, effectively identifying the best solutions.

3. The principles of conduct

BASE S.p.A. conducts its internal and external operations in accordance with the principles set out in this Ethical Code, in the belief that business ethics must be pursued alongside business success.
Integrity, transparency, rectitude, and propriety mould the action of the Company.

BASE S.p.A., in particular:

• strives after excellence and competitiveness in the market by offering its customers high-quality services that provide an effective response to their needs;
• ensures all its stakeholders fully transparent on its action, without compromising the confidentiality entailed in running its business and ensuring its commercial operations are competitive: for this reason the addressees of the Code must observe the utmost confidentiality regarding the information acquired or derived through or when carrying out their functions;
• undertakes to champion fair competition, a vital requirement in the pursuit of its own self-interest and a guarantee for all market operators, for customers and for stakeholders in general;
• eschews and condemns the recourse to any conduct that is illegal or in any way improper as a means of securing its economic aims, the latter being pursued solely through the excellence of its performance in terms of innovation, quality, and economic, social, and environmental sustainability;
• safeguards and develops its human resources;
• subscribes to the principle of equal opportunity in the workplace regardless of sex, marital status, sexual persuasion, religious faith, political and trade-union views, skin colour, ethnic origin, nationality, age and disability;
• pursues and endorses the protection of internationally proclaimed human rights;
• makes responsible use of resources, consistent with the aim of achieving sustainable development, having regard to the environment and the rights of future generations;
• will not tolerate corruption in any guise or form, even in places where such activity is admissible in practice, tolerated, or not challenged in the courts. For this reason, addressees of the Code are prohibited from offering complementary gifts or other benefits that could constitute a breach of rules, or are in conflict with the Code, or might, if brought to public notice, damage the Company or just its reputation;
• defend and protect its corporate assets, and shall procure the means for preventing acts of embezzlement, theft, and fraud against the Company;
• condemns the pursuit of personal interest and/or that of third parties to the detriment of social interests;
• is committed, within the Company and in its dealings outside, to complying and securing compliance with local national legislation, as befits its role as an active and responsible member of the communities it operates in;
• creates organizational mechanisms to prevent breaches by its employees and non-employee workers of the rules and principles of transparency, propriety, and fairness, and it checks that these rules are adhered to and put into effect.

4. Internal control system

The efficiency and effectiveness of the internal control system are essential for operating the business in keeping with the rules and principles of this Code.
Internal control system refers to a mix of aids, activities, procedures, and organizational units that, through an integrated process of identification, measurement, and monitoring of major risks, secures the following aims:

the efficacy and efficiency of business operations, so also guaranteeing that documents and decisions are traceable;
the reliability of accounting and management information;
compliance with laws and regulations;
the safekeeping of Company assets.

For the purposes of the above the addressees of the Code are required to contribute to the constant improvement of the internal control system.
In carrying out their work and in connection with their separate spheres of responsibility, the control and supervisory bodies, Internal Audit, and the independent auditors enjoy direct, full, and unfettered access all personnel, activities, operations, documents, archives, and assets of the business.

5. Stakeholders (*)

BASE S.p.A. adopts a multi-stakeholder approach, meaning that it pursues long-term and sustainable growth intended to represent a fair compromise between the expectations of all those who interact with the Company and the companies in it.

CUSTOMERS
BASE S.p.A. bases the excellence of its products and services on non-stop innovation. Its goal is to anticipate customers’ needs and meet their demands with an immediate and professional response that is delivered with propriety, courtesy, and unstinting cooperation.

HUMAN RESOURCES
BASE S.p.A. recognizes the crucial importance of human resources, in the belief that the key to success in any business is the professional input of the people that work for it in a climate of fairness and mutual trust.
BASE S.p.A. safeguards health, safety in the workplace, both through management systems that are continually improving and developing and by promoting an approach to health and safety based on prevention and the effective handling of occupational risk.
BASE S.p.A. considers respect for workers’ rights as fundamental to the business.
Working relationships are managed placing particular emphasis on equal opportunity, on furthering each person’s career development, and on turning their diversity to account by creating a multi-cultural working environment.

SUPPLIERS AND OUTSIDE WORKERS
Suppliers and outside workers play a key role in improving the competitiveness of the business.
While seeking the keenest competitive edge, the Company bases its relations with suppliers and outside workers on fairness, impartiality, and ensuring equal opportunities for all parties concerned.
Base S.p.A. requires that its suppliers and outside workers comply with the principles and rules in this Code.

COMPETITORS
Base S.p.A. acknowledges that proper and fair competition is essential if businesses and markets are to flourish. In operating its own business it embraces competition based on innovation and on the quality and performance of its products. The Company and all their employees must eschew unfair commercial practices and, under no circumstances, does a belief that they are acting in the interest of the Company justifying conduct that is at variance with these principles.

6. Compliance with the Code

BASE S.p.A. requires that the conduct of all addressees of the Code is consistent with the general principles it states.
Accordingly, there is a duty on all addressees of the Code to avoid any action that conflicts with those principles.
BASE S.p.A undertakes that it will adopt procedures, rules, or instructions for specifically ensuring that the values affirmed herein are reflected in the effective conduct of the Company, its employees, and its outside workers.
A breach of the principles and content of this Code may amount to non-performance of the primary obligations under the offender’s employment agreement and/or their contract, with the possibility they may face disciplinary measures as provided in legislation, collective agreements, or by contract.

(*) Stakeholders
While there is no unambiguous examples of stakeholders valid for every company, commonly identified as those stakeholders with an interest material in relation to the business, such as shareholders / partners, employees, customers, suppliers and other partners commercial institutions (including the authority to control and supervise the public administration), local communities.