This is a public document that identifies, without claiming to be exhaustive, ethical principles and criteria of conduct, the behavior towards the environment, health, work that team byte deems to be fundamental and towards which it directs its behavior. The forecasts are
therefore binding both for the managers and for all employees, collaborators and consultants of the Company, as well as for anyone who has relations with them.
1.1 Unethical behaviors The behaviors deemed to be unethical are those that are assumed by single people, several people or organizations of people working on behalf of team byte and which constitute a violation of the rules of civil coexistence and correct social and commercial relationships, as provided for and governed by laws and regulations. The assumption of unethical behavior compromises relations between the Company and its business partners, between the Company and its employees and collaborators, as well as between the Company and its institutional, business and financial, public and private interlocutors.
1.2 The value of reputation
A good reputation is an essential intangible resource of team byte, especially in relation to the “mission” it has given itself. Outside of it, a good reputation constitutes a basic element of trust for customers, and an element of attraction for the best human resources who have an interest in working with the Company. It is also a key element for relations with public institutions and for business and financial interlocutors. Within the Company, constantly maintaining behavior based on ethical principles allows decisions to be taken and implemented, mitigating possible elements of conflict, as well as organizing work in a climate of mutual respect, without necessarily having to resort to authoritarian interventions.
2.2 Compliance with the rules
As part of their professional activity, the employees, managers and collaborators of team byte are required to diligently comply with the laws in force, this Code of Ethics, company procedures, internal regulations and, where applicable, the rules of professional ethics. In no case can the pursuit of the Company’s interest justify conduct in violation of these rules.
2.3 Conflicts of interest
In conducting any activity of interest to the Company, situations where the subjects involved are in conflict of interest must always be avoided and promptly resolved. A conflict of interest is deemed to exist in the event that an employee, collaborator or manager pursues a goal other than that pursued by team byte, or voluntarily gets a personal advantage for himself/herself or attempts to obtain a personal advantage when performing activities carried out in the interest of the Company, or procure it to third parties. The violation of these principles shall be subject to penalties.
2.4 Confidentiality The employee, collaborator or consultant must know and implement the provisions of company policies regarding information security, including the information in electronic form, to guarantee its entirety, confidentiality and availability. Any information obtained by an employee and/or collaborator in relation to their business is owned by team byte.
The information is processed by team byte in full compliance with the confidentiality and privacy of the interested parties, in accordance with current legislation on the subject. In particular, the Company:
has defined an organization for the processing of information, which ensures the correct separation of roles and responsibilities;
makes the third parties who intervene in the processing of information sign confidentiality agreements.
The employee, collaborator or consultant who becomes aware of information not in the public domain must use the utmost caution and care in using such information, avoiding its disclosure to unauthorized persons – both inside and outside the company. This obligation will remain in force even after the termination, for any reason, of the employment relationship.
2.5 Value of human resources
team byte employees and collaborators are a key factor for business success. For this reason, team byte protects and promotes the value of human resources in order to improve and increase the experience and knowledge of each employee and collaborator.
Maintaining a serene, stimulating and respectful work environment is one of the principles of team byte, as well as promoting a policy of personal and professional growth to guarantee career development based on skills, professionalism and merit. The Company ensures a suitable training and awareness program on issues pertinent to the Code of Ethics.
2.6 Fairness in the relations with employees
In the hierarchical relationships with employees team byte ensures that there are no occasions when the exercise of the principle of authority is harmful to the dignity and professionalism of the employee. The Company shall make its own organizational choices while safeguarding the professional value of employees.
2.7 Integrity of the person
team byte is committed to protecting the physical and moral integrity of its employees and collaborators, ensures working conditions that respect individual dignity and takes care of the safety and hygiene of the workplace.
3 Ethics in the activity of the Corporate Bodies and in the Corporate Organization
3.1 Activity of the corporate bodies The activity of the corporate bodies of team byte is based on full compliance with the rules established by the Articles of Association and current legislation.
3.2 Watchdog pursuant to Leg. Decree no. 231/ 01
The managing body of team byte intends to adopt the Watchdog in accordance with the provisions of Legislative Decree no. 231/01. This Body shall verify the uniform application of this code of ethics, as well as compliance by each employee, collaborator and all those who cooperate in pursuing the purposes of the Company, of the “Organization, Management and Control Model” for pursuant to Legislative Decree 231/01. The Watchdog shall be configured as a staff unit in a top position and will report the results of its activities, any critical issues and will suggest any corrective and improvement measures directly to the Board of Directors.
4 Ethics in relations with third parties
4.1 Presents, free gifts and benefits In relations with officials of public institutions, public officials and persons in charge of public services, directors, managers, employees and collaborators of the Company, it is forbidden to give or promise money or any benefit (for example: presents, free gifts, benefits) of significant value in any form (except in the case in which these have a moderate value and fall within the ordinary practices and customs). This prohibition applies both in the event that the conduct is carried out in the exclusive interest of the agent, and when it is implemented with the intention of illegally procuring an advantage for the Company. Directors, managers, employees and collaborators must not accept presents, services, free gifts, gratuities or benefits in any form that may affect the actions to be taken in the performance of their job duties. The above cannot be circumvented by resorting to third parties.
4.2 Donations to the Public Administration for charitable or philanthropic purposes
Any donations for charitable or philanthropic purposes are made to organizations and Institutions that have the right to receive them in accordance with the laws in force. These payments shall be adequately documented.
4.3 Economic relations with political parties and trade union organizations
Any funding to political parties in Italy and abroad shall be carried out by team byte in compliance with the current legislation. The Company refrains from taking initiatives that may directly or indirectly constitute forms of undue solicitation of political or trade union representatives or political or trade union organizations.
4.4 Relations with suppliers
The choice of suppliers and the purchase of goods and services are made on the basis of objective assessments of competitiveness, quality, possession of technical/professional requirements, integrity and reliability. The stipulation of a contract with a supplier must always be based on extremely clear relationships, avoiding forms of dependence.
4.5 Relations with agents team byte may make use of agency contracts in order to promote the finalization of contracts for sale/provision of services.
The stipulation of the contract must be based on a relationship of mutual esteem and clarity and always referring to the ethical values of team byte. Agents, in carrying out their professional duties, are required to comply with the Code of Ethics. Any commercial incentive must be in line with common market practices, must be approved, as well as registered in compliance with the current regulations.
4.6 Contributions and other sponsorhips
team byte may adhere to requests for contributions, limited to proposals from non-profit organizations and associations. The sponsorship activities – which may concern the social, environmental, sport, entertainment and art topics – are intended only for events or bodies that offer a guarantee of quality and in respect of which any possible personal or business conflict of interests may be excluded.
5 Ethics in relations with employees
5.1 Staff selection
The evaluation of the staff to be hired shall be carried out on the basis of the correspondence of the candidates’ profiles to the company needs, safeguarding equal opportunities for all interested parties. The information requested is strictly connected to the verification of the aspects included in the professional and psycho-aptitude profile, in compliance with the private sphere and the opinions of the candidate.
team byte shall adopt appropriate measures to avoid favoritism, nepotism or forms of clientelism in the selection and recruitment phases of personnel within the limits of the available information.
5.2 Establishment of the employment relationship
The staff shall be hired with an employment contract in the manner provided for by the regulations and collective bargaining in force. No irregular or “off the books” positions shall be permitted. Before the establishment of the employment relationship, each employee shall receive adequate information relating to the regulatory and salary content of the relationship itself so that acceptance of the assignment is based on actual knowledge of it.
5.3 Staff management
team byte shall avoid any form of discrimination against its employees. In the context of personnel management processes, the decisions taken are based on the correspondence of the profiles possessed by employees to the needs of the Company, as well as on merit considerations.
5.3.1 Health and safety
team byte shall adopt the required measures to ensure the best possible protection of health, safety in the workplace and the prevention of all potential forms of risk with a view to continuous improvement. This policy is applied indifferently to both its employees, collaborators and consultants of external companies. To develop and control compliance with Health and Safety management, the Company uses an implemented system, based on the shared and updated Risk Assessment Document which is periodically verified, certified by independent third parties and which refers to international standards (BS OHSAS 18001), national guidelines (UNI INAIL 2001) and the Policy for Quality, Environment and Safety. All employees, collaborators and third parties are required to thoroughly comply with all the measures required by the procedures and internal regulations of the Company on the subject of Health and Safety at work, drawn up and updated in accordance with current legislation, but also to contribute with proposals and reports.
5.3.2 Privacy protection Employee privacy shall be protected through the adoption of all measures and safeguards for the processing and storage of information required by current legislation. Any inquiry into the ideas, preferences, personal tastes and in general the private life of employees shall be prohibited.
5.3.3 Integrity and protection of the person
team byte is committed to protecting the physical integrity and moral profile of employees and to ensuring the right to working conditions that respect the dignity of the person. For this reason it safeguards workers against acts of psychological violence and contrasts any attitude or behavior that is harassing or harmful to the person, their beliefs and preferences; sexual harassment shall not be allowed.
6 Ethics of the relations of employees and collaborators towards the Company
Without prejudice to the obligations and provisions of the legislation and individual and collective bargaining in force, each employee and each collaborator must avoid behaviors that are contrary to corporate ethics, as identified in this Code of Ethics, which affect the reputation and the Company.
6.1 Information management Company information must be accessible only to authorized persons and must be protected from undue disclosure; only persons explicitly authorized by the Company may have access to internal information and are required to abide by the Company’s operating instructions.
6.2 Conflict of interest
Each employee and each collaborator is required to avoid situations in which conflicts of interest may arise and to refrain from personally taking advantage of business opportunities that they have become aware of during their activities.
7 Methods of implementation of the Code of Ethics
7.1 Dissemination and communication of the Code of Ethics
team byte shall be committed to disseminating the Code of Ethics, using all the means of communication and opportunities available such as company information and training meetings.
Employees, directors, managers and collaborators must be in possession of the Code, know its contents and observe what is set forth therein. It is the responsibility of everyone, and in particular of the management, to include the contents of the Code in training programs and refer to it in all company procedures, policies and guidelines.
7.2 Update of the Code of Ethics The Watchdog shall be able to provide support for the revision and updating of the Code of Ethics where necessary.
7.3 Supervision of compliance with the Code of Ethics
The Watchdog shall have the task of ensuring that employees comply with the rules established by the company. This body must also represent an important reference for employees and for all those who find themselves in the situation of verifying a non-compliance. The Watchdog must convene periodically to verify compliance with the internal rules.
7.4 Reports of violation of the Code of Ethics
All the figures involved are required to report any violation of the Code to their managers and the Watchdog. Any reports must be made in detail and shall not give rise to any form of retaliation.
team byte may adopt disciplinary measures against an employee who behaves in a manner that does not comply with the Code of Ethics, in accordance with the provisions of the relevant sector National Collective Bargaining Agreement, including termination of the contract in the most serious cases. Any violation by the main suppliers and agents of the information principles of this Code of Ethics must be notified by the Company to them and will allow the Company itself not to make use of the supplier’s services or to terminate any existing contracts or relationships.