Code of conduct

B.R.T. S.p.a. ( hereinafter called BRT or Company) is the supplier company of all Bonfiglioli Group spare parts worldwide, ensuring an accurate high level service, especially in the resolution of customer application problems.
Original spare parts are available in 24 hrs throughout Italy and Europe, thanks to our organizational skills and a careful management of stock that keeps available a significant amount of parts (more than 10,000 items) in the warehouse.

Thanks to its strategic geographical location, BRT is able to optimize the delivery of critical spare parts in order to always keep a high-level quality service level for all Bonfiglioli products. A special software application efficiently manages the flows and the availability of the items, always keeping a safety stock capable to meet even the most unexpected request from market in terms of quantity and quality .
B.R.T. is an example of Company devoted to after-sales this is one of our keystones on which we base our ability of satisfying the Bonfiglioli Group customers.
 

Vision/Mission
After-sales service. Bonfiglioli Group spare parts supply.

Values
Consistency, Determination, Transparency, Team spirit.

1- Beneficiaries and Control Bodies

1.1 Beneficiaries
The recipients governed by this Code of Conduct include all Boards of Directors, Boards of Statutory Auditors, shareholders, auditors, managers, employees, contractors, consultants, suppliers, customers, partners and contractual counterparts of B.R.T. and all persons and organizations keeping business relationship, even temporary, with B.R.T in the pursuit of common objectives.
Each of the above recipients, as a beneficiary of this Code of Conduct is required to familiarize with the this Code and its relevant principles, in order to actively contribute to its implementation in all its parts and for reporting to the Supervisory Board any violation of the ethical principles contained herein.

1.2 Governing Bodies
Given the findings of risk analysis carried out in the company pursuant of Legislative Law n. 231/01, considering also size and characteristics of this company, in compliance with the requirements of Art . 6 c . IV , and 7 of that Decree, BRT has decided to entrust the Board of Directors as responsible for supervising the compliance with the adopted Organizational Model ( MO ) and its regular updates.
In exercising this function, the Governing Body will draw on the assistance of Company internal Quality Dept. in compliance with protocols and procedures.

We will indicate, hereinafter, the references for reporting:
- Any potential or occurring violations of this Code of Conduct;
- Any request of clarification about the understanding or the conformity of behavior to this Code

Controlling Body:
BRT spa, Via Castagnini, 2-4 ( ZI Bargellino ) 40012 Calderara di Reno ( BO )
email: gabriele.bongiovanni@bonfiglioli.com

2 - Ethical General Principales

2.1 Business management
The behavior in the conduct of business by the Beneficiaries shall be directed with the utmost fairness, transparency, comprehensibility and respect for Laws, so that anyone who deal with BRT is capable of taking their own decisions conscious of their interests.
Misreading or personal interpretations of the rules of this Code of Ethics in business relationships are not allowed.

2.2 Conflict of interests
Activities that involve conflicts of interest that might interfere with the ability of taking impartial decisions at the expense of the interests of BRT must be avoided.
In all relationships with BRT Recipients must act within Law and Ethical values, with absolute prohibition to recourse to favoritisms, corruption or collusive practices in order to obtain advantages for themselves or for others.

2.3 Diversities respect
BRT does not tolerate unequal treatments, according to sex, religious belief or culture because each individual is measured in relation to his actions, his role and tasks only.
All those who interact with BRT must keep a behavior that is shared and respectful of civil society, in compliance with the principles of this Code of Conduct.

2.4 Inhibition of child labor
BRT prevents the exploitation of child labor expressly prohibiting the use of workers under the Italian starting working age by Laws and by regulations of the place where the service is delivered in its assembly facilities.
The company also prohibits the Recipients to establish business relationships with suppliers that employ minors under that age and against the Laws of the place where the service is delivered.

3 - Ethical Principles against third parties

3.1 Relations with Public Institutions
Corporate functions expressly delegated or provided with specific powers are authorized to represent BRT in relation with both Italian or foreign institutional partners for Business purposes.
These business relations must be based on principles of fairness and transparency and in harmony with Laws and this Code of Conduct, in order to avoid any possible conflict of interests.
Transparency and fairness in the management of business relations with Italian or foreign public institutions aim to ensure there are no situations in which the collaborators of the companies might directly or indirectly promise or offer money or may give any other benefit to members of the Authority institutions in order to obtain profits or paybacks for themselves or for the Subjects who work with the company.

3.2 Relations with Mass Media
Relationships with Mass - Media are critical to convey to the public facts, data or activities that characterize the BRT daily work.
Given the delicacy of these relationships, these must be entertained by those who are responsible and expressly delegated to this task only, or entertained directly by the Control Bodies.
Beneficiaries who, in part of their work or in the name and on behalf of the company, are reported to have relations with mass-media, must be expressly authorized in advance by their departments on the content of their interventions.
The information transmitted must be complete, consistent, straight and transparent.

3.3 Relationships with Customers and Suppliers
The goal BRT continuously tends to is the satisfaction of customers’ needs and requirements.
This represent the real treasure of the company: this awareness imposes the search for excellence in interactions with customers, which can only be achieved through respect of ethical values and business procedures.
Suppliers are important Partners for BRT and must preserve relations based on principles of fairness and loyalty.
Suppliers must therefore be identified according to objective parameters that take into account the expertise, the relationship between quality of goods and / or services offered, equality of prices, support level and a shared business goals and expectations.
Contracts signed with suppliers must be based on extreme clarity and transparency, avoiding constraints that may result in excessive form of abuse and / or dependence.
BRT does not admit that its Associates provide or receive to / from its suppliers gifts of any kind that may in some way affect the transparency and the integrity of business relations.
BRT will verify that all its suppliers operates in accordance within Laws and Code of Conduct.

3.4 Relations with Competitors
BRT believes that a modern, free market can be considered as such only if there is an appreciable degree of fair competition.
Competitors are part of the complex variables that a company must contemplate taking decisions and choosing its strategies. Therefore, these aspects must be always guided by the principles of this Code of Conduct.
Integrity, fairness, transparency and compliance with Laws and dynamic competition are the elements that distinguish the actions of our Commercial Department.
BRT is committed to the principles of fair competition protected by National and European Laws and will not create relationships with suppliers that could influence the free competition within the market in which they operate.

4 Ethical Principles in the field of Corporate Governance

4.1 Treatment of confidential information.
Confidential information about data, strategies and business goals must be learnt and disclosed by responsible persons expressly delegated to this task only.
Confidential information are also those related to products, their development, production processes, strategies, commercial conditions, customers, partnerships, industrial and financial operations know- how, operating results, investments, projects and technical data, marketing plans, supplier lists and purchase prices, logistics, ICT solutions and whatever else is part of the knowledge heritage of BRT business development.
Confidential information and materials that Recipients may use as part of their work are of exclusive property of BRT, who protects confidentiality and origin.
BRT is committed to protect the information about Recipients, preventing misuse always in compliance with the requirements imposed by Privacy Laws.

4.2 Treatment of "Price sensitive"
Among the confidential information particular importance has the "price sensitive" ones, that is to say information that, if disclosed, could have a significant impact on prices.
Beneficiaries who have access to "Price sensitive" information, in they working activities, shall neither disclose to unauthorized persons, nor use them to their personal advantage.
The disclosure of "Price sensitive" information to the authorized beneficiary is a task of those expressly delegated to this task only and in harmony with Laws and / or specific business requirements.

4.3 Statement of accounting and general management
All activities and actions carried out under the working skills of each Recipient must be provable. Anyone should strive for maximum transparency of accounts, based on fairness and documents reliability in accounting records.
Each recording operation and the different degrees of responsibility of those who have acted upon it to achieve the goals that have made it necessary must be easily reconstructed.
In accordance with the principles of accounts clarity and transparency, BRT is attentive to draw up financial statements and reports in accordance with correctness and accuracy and in compliance with Laws concerning accounting data.
Everyone involved in the creation of budget including administrative bodies should act transparently and truthfully and must represent the economic and the financial situation providing the vigilance and control authorities with complete, true and correct information on balance sheets.

4.4 Quality protection and corporate reputation
The quality and efficiency of the business, as well as the good reputation of the company, are a inestimable heritage based on over 15 years of activity in the name of transparency and honesty.
Therefore, any conduct not complying with the ethical values of the Code may affect the image and good reputation of BRT, gained in Italy and abroad.
Therefore, with his behavior any Recipient of this code is asked to contribute to the preservation of the company's assets, in particular the protection of the good reputation of the company, both in the workplace and outside of it.

4.5 Protection of corporate assets
Every Recipient of this Code is directly and personally responsible for the care, protection , efficient, proper preservation and use of assets, both tangible and intangible, assigned by the company.
Company Assets, whether tangible or intangible properties, entrusted to Beneficiaries to carry out professional tasks could not be used for unauthorized personal purposes. Activities not included in their own responsibilities are also prohibited, if carried out during working hours.
It is expressly forbidden to use computer resources for purposes other than those permitted by the policies of company security or to engage illegal conducts.
It is also forbidden the use of software not expressly authorized or illegally obtained.
BRT guarantees the respect for intellectual property through the express prohibition of the use of these resources, without a prior formal authorization.

5 - Ethical principles within staff relationships

5.1 Impartiality in Human Resources management.
BRT recognizes the own distinctive values, capabilities and potentiality of each employee. Workforces are considered a competitive resource and for this reason the company offers a work environment that fosters the conditions for both personal and professional development.
BRT has the duty to ensure fairness and equity in the recruitment, training and management of human resources, offering equal employment opportunities to all employees by prohibiting conducts that may appear discriminating against other people.
All those who work in the company should be aware that there is neither prejudice nor discrimination in any of their evaluations, because selections are based on meritocracy.

5.2 Health Protection, safety and working environment
BRT believes it is important to spread the safety culture.
The company pursues the reduction of risks for physical integrity of all of its employees, using informative documents and training as means of empowerment ensuring health protection and safety in the workplace in accordance with requirements and Laws.
BRT is committed to respect and maintain the working environment absolutely compatible to the protection of the health of the employees, trying not to create conditions of discomfort, even psychological, contrasting any discriminatory attitude or persecution. The responsible authorities constantly monitor the working conditions for keeping an optimum level, in compliance with Laws and adopting all the instruments and controls necessary for achieving this purpose.
The integrity of human resources is a core value for BRT : persecutions and / or attitudes, both explicit and suggestive, that may disturb the least sensitivity, undermining the dignity, the respect and the integrity, both physical and psychological of human resources are not tolerated.

5.3 Environment protection
BRT invests in activities valuing natural resources with a constant attention in preserving the environment.
Environmental policy is based on an awareness that involves all employees, starting with simple behaviors, but very useful, such as recycling of certain materials ( toner , batteries , paper , plastic , etc . ) that focuses the attention on energy saving.

6 - Adoption and updates and / or changes in the Code of Conduct
The present Code of Conduct is adopted by resolution of the Board of Directors dated __________ with immediate effect from that date. The company is committed to bring the attention of all its Collaborators on principles of the Code of Conduct using effective and suitable communication channels. Every update, amendment or addition to this Code is a guarantee of its effectiveness and denotes its reaction to changes.
Updates and / or amendments that may become necessary must be approved by CEO. The authority of point 9 verifies the effectiveness of the Code and reports to CEO the necessity of amendments.

7 - Violation of Code of Ethics and penalty system
The Code of Conduct is an integral part of the contractual obligations which bind the company with all Beneficiaries .
Violation or non-application of any part of this Code by Beneficiaries constitute a breach in contracts; for employees it is a disciplinary transgression, resulting in the adoption, in the latter case, of disciplinary sanctions proportionate to the severity of the faulty behavior, and, in some cases, also may result in a claim for damages, both material and/or of company reputation, but always in compliance with Labor Contracts, Article . 7 of Law 20 May 1970 n . 300 , as well as other additional Laws.
The non-application of all or part of the Code of Conducts, by external Recipients ( Consultants , Suppliers , Partners etc . ) constitutes reason for the termination of the partnership.