This Code of Ethics, or Business Conduct Code, is a key tool that establishes the standards for behavior, corporate ethics, and operations that Beta-Trans S.p.A., its employees, and collaborators must reference, be inspired by, and conform to in their relationships with internal and external stakeholders, such as clients, business partners, and public and private entities. These same rules and principles must be observed within the company, as well as in the relationships between employees and the company itself.

Legislative Decree No. 231 of June 8, 2001 - hereinafter referred to as the Decree - "Regulation of the Administrative Liability of Legal Entities, Companies, and Associations, Including Those Without Legal Personality, Pursuant to Article 11 of Law No. 300 of September 29, 2000" introduces the criminal liability of entities in relation to any crimes committed to the advantage of the entities' assets, as well as to the benefit of their economic interests. The drafting of this document takes into account the provisions of the aforementioned Legislative Decree 231/01. It constitutes the document through which a corporate prevention and control system can be institutionalized and managed, aimed at preventing the commission of offenses foreseen by Legislative Decree 231/2001. Beta-Trans S.p.A. considers the adoption of this Code essential and useful, particularly in the context of the company's project that guides the establishment and management of business relationships with clients, all based on an organizational model that is ethical and compliant with legal, regulatory, and behavioral standards. The company believes this to be a crucial tool and condition for the success and promotion of its image with current and potential clients, as well as with business partners.

This Code of Ethics, or Code of Conduct, is adopted by Beta-Trans S.p.A. and constitutes an integral part of the Organization, Management, and Control Models as required by Legislative Decree No. 231 of June 8, 2001. The Code takes effect from the date of its publication within the company through the corporate intranet (in Italian) and the website (in both Italian and English).

The principles of conduct and rules outlined in the Code of Ethics form the foundation of the corporate culture and represent the key values guiding the Company’s operations in the market. Consequently, the Company is committed to complying with the provisions of the Code in the execution of all its activities, ensuring that these principles underpin the actions of the Company, its directors, executives, employees, collaborators, clients, and suppliers. Any conduct that is contrary to or inconsistent with the Code of Ethics does not align with the culture of Beta-Trans S.p.A. and, as such, must not be undertaken but rather reported, addressed, and, if necessary, sanctioned.

Beta-Trans S.p.A. requires compliance with the principles and rules of conduct set forth in this Code of Ethics from all individuals with whom it maintains employment, collaboration, or commercial relationships, in any case operating under the direction, dependence, or guidance of Beta-Trans itself. Specifically, the following individuals are bound by this Code: directors, executives, employees, and collaborators. Furthermore, professionals, suppliers, and business partners—i.e., professional clients—must accept adherence to this Code as a fundamental condition for establishing new commercial relationships with the Company. Compliance with the provisions of this Code by all Recipients contributes to the achievement of the Company’s objectives. Consumers, public administrations, and entities operating under a legal monopoly are not considered business partners. All Recipients have a duty to be familiar with the content of this Code of Ethics, understand its meaning, and seek clarification if necessary. All companies within the Beta-Trans S.p.A. Group are required to fully adhere to this Code. If other Group companies choose to adopt their own codes of ethics, such adoption must be coordinated to ensure consistency and alignment with best practices.

Beta-Trans S.p.A. has always guided its conduct and business strategies according to the principles outlined below, which serve as behavioral standards aligned with the Company’s core values.
1. Legality: Beta-Trans S.p.A. promotes and requires from all parties involved in its business operations a constant commitment to compliance, understanding, and proper interpretation of Italian laws as well as the regulations of the countries in which the Company operates. Additionally, it ensures fair cooperation with public authorities. In particular, Beta-Trans S.p.A. refrains from engaging in any unlawful business activities and imposes the same prohibition on its business partners, with the penalty of immediate termination of any relationship in case of non-compliance. The Company also places great importance on adherence to the Italian Constitution, as well as the laws and regulations set forth in the Highway Code.
2. Honesty, Transparency, and Fairness: Beyond legal obligations, the Company promotes honest and good-faith behavior in dealings with employees, collaborators, and business partners, both in pre-contractual and contractual phases, as well as in any extra-contractual interactions. Likewise, it demands honesty and transparency in relations with customers. All Recipients of this Code, within the scope of their competence and responsibility, commit to the utmost truthfulness, transparency, and completeness of both verbal and written communications arising from their activities.
3. Responsible Profitability:In pursuing its profit objectives, the Company assumes responsibility toward the communities in which it operates and encourages its stakeholders to adopt the same sense of responsibility and awareness.
4. Promotion of Human Capital: Beta-Trans S.p.A. places great emphasis on this principle. The Company is committed to managing its workforce in a way that fosters a healthy, welcoming, and pleasant work environment. It promotes and strictly enforces labor protection regulations and ensures the correct application of legal employment contracts. The Company is dedicated to enhancing the skills and talents of each individual, fostering an atmosphere of collaboration, courtesy, and mutual respect. Beta-Trans S.p.A. seeks to work with competent professionals to create an environment where employees and collaborators can fully express their potential and be recognized based on their merits. The Company firmly believes in a workplace culture where everyone can make a difference. It continually provides opportunities and incentives for a diverse group of professionals, offering ongoing training and development programs to ensure that employees and collaborators remain highly efficient in their roles and can build long-term relationships within the Company. All employees, clients, and suppliers have the right to be treated equally and with respect. Beta-Trans S.p.A. does not discriminate based on race, origin, disability, age, religious beliefs, or sexual orientation. The Company provides a work environment free from racism and discrimination, ensuring that all decisions are based on qualifications, experience, and professional criteria.
5. Health and Workplace Safety Protection: The Company considers the health and safety of its employees, collaborators, customers, and any other individuals engaging in commercial relationships with Beta-Trans S.p.A. as a top priority. Therefore, it actively promotes and enforces compliance with workplace health and safety regulations, providing clear behavioral guidelines focused on caution and diligence. Beta-Trans S.p.A. consistently fulfills its obligations regarding social security and insurance contributions for its employees and expects the same level of commitment from its business partners.

The Company is committed to providing high-quality services, enhancing customer satisfaction and loyalty, and positioning itself as the preferred choice among its competitors. Beta-Trans S.p.A. offers comprehensive logistics and customs services, including simplified import and export procedures, as well as customs and VAT warehousing, allowing clients to meet their specific operational needs efficiently. As recognized by both the Company’s team and its clients, Beta-Trans S.p.A.’s reliability is affirmed by various achievements and certifications.In particular, its unwavering commitment to service excellence is demonstrated by:
Authorization from ENAC (Italian Civil Aviation Authority) and the Customs Agency to operate within Malpensa Airport, providing ground handling services for cargo operations.
The prestigious designation of "Regulated Agent," ensuring compliance with strict security protocols.
The attainment of the AEOF certification (Authorized Economic Operator Full – Customs and Security), officially recognizing Beta-Trans S.p.A. as a trusted Authorized Economic Operator (AEO).
The Company is also dedicated to offering its services with full transparency and integrity, firmly believing that these principles are key to fostering long-term customer loyalty. Its commitment to availability and problem-solving ensures timely and competent support. Beta-Trans S.p.A. does not engage in any business relationships that could compromise its reputation. Another fundamental pillar of the Company’s operations—detailed further in this document—is the strict protection of client privacy.

Beta-Trans S.p.A. requires all individuals with whom it maintains employment or commercial relationships to comply with the principles and rules of conduct outlined in this document. Specifically, the Code is binding for: Directors, Executives, Employees, Collaborators. Furthermore, acceptance of this Code is an essential condition for professionals, suppliers, and corporate clients seeking to establish new business relationships with the Company.

The Company is committed to generating value for its stakeholders by providing comprehensive and high-quality services, offering competitive and diversified solutions. All decisions are made promptly yet prudently, avoiding unnecessary delays. Beta-Trans S.p.A. maintains a transparent approach toward its stakeholders, ensuring that all relevant information is communicated in a timely manner.

Beta-Trans S.p.A. requires its workers to demonstrate constant commitment, competence, professionalism, and punctuality. The Company also mandates adherence to company hierarchies, procedures, rules, and practices—whether written or unwritten—that govern its operations, as well as the instructions provided by supervisors.Furthermore, Beta-Trans S.p.A. expects all its employees and collaborators to uphold principles of fairness, ethics, good faith, courtesy, non-discrimination based on race, gender, religion, and to show respect in interpersonal relationships with colleagues, clients, and suppliers. Beta-Trans S.p.A. strictly prohibits its employees and collaborators from accepting or requesting any compensation or other benefits in relation to the performance of their duties, except for gifts within the usual commercial practice and of modest value. Newly hired employees are required to understand and accept this Code of Ethics as part of their successful integration into the Company. This Code of Conduct applies to all employees, collaborators, clients, and suppliers of Beta-Trans S.p.A. Any clarifications can be sought through discussions with the designated supervisors.

Anyone in the capacity of director, worker, or business partner of Beta-Trans S.p.A. who becomes aware of a violation of the Code by those obligated to comply with it, is required to promptly report it to the management of Beta-Trans. Additionally, recipients of a procedure, contractual clause, practice, directive, or order that clearly contradicts the Code of Ethics, whether they are employees, collaborators, or business partners, are obligated not to follow the procedure, clause, practice, directive, or order given, and to report the issue promptly to the Board of Directors, without facing any liability for doing so. Recipients of a procedure, contractual clause, practice, directive, or order that may potentially conflict with the Code of Ethics are required to adhere to the mandatory procedure, clause, practice, directive, or order issued, while also promptly notifying the Board of Directors of the situation.The Company is committed to preventing any form of retaliation against employees who raise legitimate concerns or issues related to, or report suspected violations. If necessary, the Company will maintain confidentiality regarding the individual who raised concerns for review by the Board of Directors.

In the course of daily operations, we entrust our employees with a variety of sensitive information that must be protected, as stipulated in the employment contract. All data resulting from employment relationships through clients are confidential and must not be disclosed to unauthorized individuals.

The Board of Directors of Beta-Trans S.p.A. is responsible for overseeing compliance with this Code of Ethics by all obligated parties. The Board is required to receive reports and take appropriate action in accordance with the Regulations. Reports submitted to the Board, in any form, will not result in any liability for the individual who has made or disclosed the report. The Board can be contacted via email at: betatrans@betatrans.it, or by sending a sealed letter to Beta-Trans S.p.A., Via Londra 7/9, Segrate, clearly marking the envelope with the wording "CONFIDENTIAL – BOARD OF DIRECTORS." If anonymity is not preferred, reports should include the clear identification of the sender, along with their signature. If submitted by email, the use of a personal company email account or a certified email address is required. The Board of Directors will report any submissions containing defamatory or slanderous content to the judicial authorities.

Considering the value of the information related to the Company's clients, as it forms the basis for Beta-Trans S.p.A.'s ability to offer services tailored to their specific needs, the Company recognizes that customer trust in its operations and integrity is a vital part of its assets. Therefore, the Company prioritizes the commitment to safeguarding customer information and using it appropriately. It is essential that all individuals involved in client relationships protect all information, especially confidential data, in compliance with applicable laws, security standards, and confidentiality requirements. Furthermore, Beta-Trans S.p.A. is committed to ensuring that names and information related to clients or business partners are used solely for purposes that justified their dissemination to the company, unless the law allows for their use for other purposes.

Beta-Trans S.p.A. requires that, at every stage leading to the conclusion of a commercial contract with clients and collaborators, the individuals responsible for the negotiations act solely in the best interests of the Company. In conducting any activity, Beta-Trans S.p.A. expects that anyone involved avoids situations of conflict of interest. A conflict of interest refers to situations where an individual pursues interests that differ from the Company's mission or personally benefits from business opportunities or activities within the Company. If a conflict arises between personal interests and those of the Company or its clients, the individuals involved must promptly inform their superior, who, if deemed necessary, may revoke the mandate and replace the individual, or alternatively, provide binding instructions. The Company explicitly and absolutely prohibits the misuse of Beta-Trans S.p.A.'s name, facilities, or relationships for the benefit of any individual or in other work contexts. Except for business-related uses and considering the circumstances, no personal benefit unrelated to the contract's subject matter may be requested, accepted, or offered during or after negotiations. Furthermore, accepting gifts, services, loans, or preferential treatment from clients, suppliers, or others—whether directly or through family members—in exchange for existing or future business relationships is strictly prohibited. Contractually agreed compensation for the performance of work or the provision of goods or services must be fair and not significantly deviate from market values, considering the circumstances, and as long as the service does not require special protections. Gifts and presents are permitted, provided they are of modest value and in line with common business practices.

If an external party attempts to obtain information from an employee regarding the company, its employees, collaborators, or clients, such information must not be provided unless prior and appropriate authorization has been granted. However, if authorization has not been issued, the individual receiving the request is obligated to forward it to the designated person responsible for such matters.

In its relationships with the market, Beta – Trans S.p.A. rejects cooperation with commercial partners who have engaged in illegal labor practices, the use of child labor, slavery, human trafficking, the smuggling of irregular immigrants, or who are involved, even indirectly, in terrorist activities or the subversion of democratic order. The company also rejects cooperation with partners involved in criminal organizations (especially mafia-type organizations) or those responsible for serious acts of corruption toward public officials. Furthermore, Beta – Trans S.p.A. refuses to work with commercial partners who have been involved in or are responsible for serious environmental pollution, including air, soil, and water contamination, or environmental disasters.Beta – Trans S.p.A. seeks to promote a free and democratic civil society, based on the respect for human dignity, family units, and the cultural and natural environment. The company firmly condemns any form of slavery, discrimination, and the abusive use of violence or threats. If Beta – Trans S.p.A. decides to operate in countries where democracy is not a fundamental value, or where European standards of freedom and human dignity are not guaranteed, the company commits to refusing cooperation with commercial partners who use slave labor, child labor (as defined by UN conventions on the matter), or who are involved, even indirectly, in terrorist activities. Each commercial offer will be carefully reviewed by the company using selection mechanisms that assess the guarantees of legal compliance, respect for human dignity, and environmental protection by potential partners.

The operations of Beta – Trans S.p.A., as well as those of all its employees, are guided by compliance with applicable regulations, with particular emphasis on those related to workplace safety. Employees and collaborators of the Company commit to following the instructions and guidelines issued by the company (in accordance with Legislative Decree 81/2008, the guidelines of which are available at the office of Arch. Gianpiero Cioli). They also commit to refraining from any actions or behaviors that could endanger their own safety, the safety of their colleagues, or that of clients within the workplace. Beta – Trans S.p.A., as well as its employees and collaborators, also commits to adhering to anti-money laundering regulations, working to apply these laws from any source, including specific and any procedural rules set by the Company itself. This is to be done with the utmost diligence and in full respect of the principle of good faith.

Beta-Trans is committed to ensuring that all data related to accounting documents complies with legal requirements and the security and responsibility standards required and all transactions must be accurately recorded.

Internal controls are those established according to the guidelines of the ISO 9001 certification.

Beta – Trans S.p.a. believes that a fundamental factor for the success of its operations is the multidisciplinary nature of its workforce. Each employee develops customized career paths to foster their talents and achieve significant and satisfying results. Every member of the company staff is selected based on their aptitude, experience, and skills. The selection process is carried out by the Board of Directors, and upon hiring, the company implements an onboarding and mentoring program aimed at training and managing the employee. The company does not tolerate any form of irregular employment; all personnel are hired with a regular employment contract specific to the transport sector.

As previously mentioned, the company holds each employee or collaborator responsible for the physical and intangible assets of Beta – Trans S.p.a., its clients, suppliers, and distributors that are under its control. The company emphasizes the principle that its assets must not be used for personal benefit, except in cases where Beta – Trans S.p.a. explicitly allows it, in accordance with the laws and local market practices. These assets include business plans, customer, supplier, and distributor information, intellectual property (software, contract models, etc.), tangible assets, and services. Telephone systems, email, and voicemail are intended for business purposes. Personal communications should be kept to a minimum. The use of email and the Internet may also constitute public communication or advertising, both of which are subject to specific regulations. Misappropriation of company assets is considered a criminal offense under the law and also constitutes a breach of duties to Beta – Trans S.p.a.

The data, records, and information owned by Beta – Trans S.p.a. that are used and managed by the company must be accurate and complete. Each employee is personally responsible for the integrity of the information, relationships, and records within their area of responsibility. The dissemination of false or misleading information to third parties, including internal or external auditors of Beta – Trans S.p.a., consultants, other company employees, or regulatory and supervisory officials, may be considered an offense and lead to serious legal consequences.

In the selection of suppliers and contractors for Beta – Trans S.p.a., employees and collaborators must ensure full alignment with the principles and content of this Code. Specifically, employees and collaborators of the company must observe the same principles in their relationships with suppliers and contractors as they do in their relationships with clients. Decisions regarding purchases should always be based on objective criteria, considering the reliability and integrity of suppliers as well as the value of their offers, taking into account both short- and long-term evaluations and objectives.

The company maintains relationships with financial institutions (banks, leasing companies, etc.) based on fairness and transparency, with the aim of collaborating in an environment of mutual respect.

Beta – Trans S.p.A. is committed to making this Ethical Code available in both paper and electronic formats for internal use within the company. However, the document is also published in a highly visible section on the company website, so that anyone can freely obtain a copy at any time. In this way, Beta – Trans S.p.A.'s business partners can access the document whenever they wish. Written or electronic communications sent to customers by the company's sales network or to suppliers by the procurement team systematically highlight the existence of the Ethical Code, along with a link to the electronic document. Every contract concluded must include the web address where the full text of the document is always accessible. The company emphasizes that if a commercial relationship is not governed by a written contract, the provisions of the Ethical Code hold the same value as the General Terms and Conditions of the contract pursuant to Article 1341 of the Civil Code.

The relationships that the Company maintains with Public Administration or any other public sector entities are based on the strictest adherence to the applicable laws and regulations, and they must not compromise the integrity and reputation of Beta – Trans S.p.A. The management of such relationships, the signing of commercial agreements, contracts, or, more generally, any kind of relationship with Public Administration or public sector entities, is exclusively reserved for the company's personnel specifically authorized for these tasks. It is prohibited for these individuals to engage in any behavior that might improperly influence the decisions of the relevant institution.Furthermore, during any business negotiation or contractual relationship, including commercial transactions, with Public Administration or public entities, Beta – Trans S.p.A. commits to not offering donations or job opportunities to personnel from the Public Administration involved in the negotiation or relationship, or to their family members. The Company also refrains from requesting or obtaining confidential information that could compromise its integrity and reputation. In dealings with Public Administration, representatives, collaborators, and employees of Beta – Trans S.p.A. are prohibited from directly or indirectly offering, or making payments or donations through third parties, to any employee or representative of the Public Administration, as compensation for actions taken in their official capacity, or to induce the performance of any act that goes against the duties of their office.