1.  Introduction

E-GAP S.r.l. (hereinafter, “E-GAP” or the “Company”) is a company operating in the field of electric mobility, energy storage and energy trading, specializing in the development, production and marketing of innovative products and services with high technological value for electric mobility in cities. E-GAP carries out its business activities with the aim of promoting the energy transition towards forms of use of resources and energy sources compatible with environmental protection and decarbonization of mobility.

Precisely with a view to the creation of sustainable and shared value, E-GAP has adopted this internal code of conduct (hereinafter the “Code”) that contains the commitments and ethical responsibilities that the Company wants to keep in the performance of business activities and in achieving the objectives of the group. In addition, this Code defines the set of values and principles, as well as the lines of conduct, which must be followed by the Recipients, as defined below.

E-GAP evaluates the value of its results also and above all with respect to the way in which they are achieved, in the firm belief that long-term success can be such only if it creates value – at the same time – for the Company, for the stakeholders, for the employees, for the customers and for the territories in which it operates. In the same way, expressly sanctioning the ethical principles of the Company generates added value and contributes to increasing the well-being of employees and customer satisfaction.

2. General Provisions

The provisions of the Code apply to E-GAP, to the “internal subjects” of the Company and to all “external subjects” that, by virtue of contractual relationships, lend their collaboration to E-GAP for the realization of its activities, meaning by this

  • internal subjects: (i) the members of the corporate bodies of the Company and (ii) tutto il personale di E-GAP, i.e. i dipendenti, compreso il top management all the staff of E-GAP, i.e., employees, including top management and collaborators bound by a fixed-term contract.
  • external parties, within the limits of the relationship with the Company, such as, by way of example and not limited to: (i) self-employed or para-subordinate workers; (ii) suppliers of goods and services, including professionals and consultants; (iii) agents; (iv) i business partners

The Company requires external parties to comply with the Code and verifies that the principles on which the activities of its business partners are based, insofar as applicable, are in line with those set out in this Code.

All internal and external parties constitute the “Recipients” of this Code. In the following pages, therefore, general reference is made to the Recipients, without prejudice to cases in which certain principles are applicable to specific internal and/or external parties.

The Code indicates the general rules of conduct that Addressees must comply with in the exercise of their respective offices and duties, including with reference to
a. obligation of confidentiality on information of a confidential nature acquired or which they have at their disposal in any case by reason of their function.
b. procedures established to carry out their activities.
c. prohibition to receive from third parties, or to give, offer or promise to give to third parties, benefits that may induce them to behave in a way that conflicts with the interests of the Company or of the entity on whose behalf they work.

The Code regulates the set of rights, duties, and responsibilities that the Company and the Recipients undertake to maintain in relation to the stakeholders with whom they interact on a daily basis as part of the performance of their activities.
The set of principles and values expressed in this Code inspires the activity of those who work in E-GAP, considering the importance of their roles, the complexity of functions and responsibilities entrusted to them for the pursuit of different purposes.

3.  General Ethical Principles

Recipients hereby undertake to abide by the following ethical principles (hereinafter, the “Principles“) in the performance of any activity performed on behalf of the Company:

3.1 kindness;

3.2 impartiality and non-discrimination;

3.3 confidentiality;

3.4 legality;

3.5 fairness;

3.6 professionalism and reliability;

3.7 sustainability;

3.8 transparency and fairness;

3.9 value of human resources;

3.10 prevention of potential conflicts of interest;

3.11 compliance with occupational health and safety regulations;

3.12 continuous improvement and quality of the services provided;

3.13 protection of competition.

3.1 Kindness

In carrying out any working activity, Recipients are required to respect their interlocutors with politeness, respect, politeness, and courtesy, according to the parameters of common sense, whether they are external or internal to the Company.

3.2 Impartiality and Non-Discrimination

In the performance of work activities of any kind, particularly decision-making, E-GAP and Recipients are required to avoid any form of discrimination based on sex, gender, ethnicity, religion, political orientation, disability, gender, age, and any other form of diversity.

3.3 Confidentiality

E-GAP recognizes confidentiality as an essential and mandatory value; therefore, the Recipients ensure the confidentiality of information and personal data being processed and the protection of information acquired in relation to the work performed. The information obtained will not be used in a manner contrary to the law or for any purpose other than that for which it was acquired.
Recipients, therefore, may not derive advantages of any kind, personal or financial, direct or indirect, from the use of confidential information, nor may they communicate such information to others or recommend or induce others to use it.
The Company’s Privacy Policy guarantees adequate security standards for the handling of personal data.

3.4 Legality

In carrying out its activities, E-GAP promotes the implementation and compliance with its internal rules and procedures, as well as with the principles of the Code, in order to prevent any violation of applicable laws.

3.5 Fairness

E-GAP in the provision of services, or in the establishment of any working relationship is committed to avoid any abuse of power ensuring fairness and equity.

3.6 Professionalism and Reliability

The Recipients are committed to ensuring that all E-GAP activities are carried out with the utmost commitment, diligence, and professionalism, protecting the reputation and image of the Company.

3.7 Sustainability

E-GAP carries out business activities with the aim of promoting the energy transition towards forms of use of resources and energy sources compatible with environmental protection and decarbonization of mobility. In this perspective, the company intends to pursue one or more purposes of common benefit and operate in a responsible, sustainable, and transparent way towards people, communities, territories and environment, cultural and social goods and activities, institutions and associations and other stakeholders.
Recipients undertake to ensure compliance with environmental obligations and to conserve natural resources, minimizing the environmental impact resulting from the performance of corporate activities, promptly reporting any situations of danger for the environment and violations of the rules of conduct and corporate procedures on the subject.
In addition, the Company and the Recipients are committed, as far as possible, to respect and protect the environment in its entirety by promoting the promulgation of green and ecofriendly policies.
In any case, E-GAP operates considering the needs of the community in which it carries out its activities and seeks to contribute to its economic, environmental, social, cultural, and civil development.

3.8 Transparency and Fairness

Relations with stakeholders are based on criteria of fairness, collaboration, loyalty, and mutual respect.

Recipients shall carry out their activities in the interest of the Company and shall therefore not be subjected to any kind of pressure.

In particular, every action, operation or transaction must be correctly recorded in the company’s accounting system according to the criteria indicated by law and the applicable accounting principles, duly authorized, verifiable, legitimate, consistent, and congruous.

The accounting documents must meet the requirements of truthfulness and completeness of the recorded data; for each accounting operation, complete and adequate supporting documentation must be kept in the Company’s records, in order to guarantee (i) the identification of the characteristics and motivations underlying the operation itself (ii) the accounting record (iii) and the reconstruction of the decision-making and authorization process.

Each employee, to the extent of their competence, acts in such a way as to ensure that all data relating to the management of the Company is correctly and promptly recorded in the accounts.

Managers and employees of E-GAP are responsible for the protection of company resources entrusted to them and have a duty to promptly inform their direct managers of events potentially harmful to the Company.

3.9 Value of Human Resources

Human resources represent an indispensable and valuable value for the development of E-GAP.

E-GAP protects and promotes the value of human resources, also contributing to increase the wealth of skills possessed by each employee and promoting the “Working in Team”. E-GAP is committed to promoting respect for the physical, moral, and cultural integrity of the person, ensuring individual dignity and safe working environments. E-GAP prohibits any and all forms of harassment – psychological, physical, and moral – against managers, employees, contractors, suppliers, customers, or visitors.

The Company is also committed to ensuring that, in the work environment, cannot find any form of discrimination based on age, sex, sexual orientation, race, language, nationality, political opinions and trade union, religious beliefs or other personal characteristics not related to work.

The Company adopts criteria of merit and enhancement of the abilities, skills, and potential of individuals in its personnel selection and management policies.

3.10 Prevention of potential conflicts of interest

The Recipients of the Code of Ethics are required to avoid any situation and to refrain from any activity that may oppose a personal interest to those of the Company or that may interfere with and hinder the ability to take, in an impartial and objective manner, decisions in the interest of the Company.

Therefore, such persons must avoid any exploitation of their position and, in particular, must exclude any possibility of overlapping or crossing of economic activities in which there is or may be a personal and/or family interest with the duties covered and/or assigned by the Company within the scope of the relations existing with it.

3.11 Compliance with Occupational Health and Safety regulations

The Company promotes and guarantees the health and safety at work of its employees and of all those who enter its offices and working environments.

The Company also undertakes to guarantee working conditions that respect the dignity of the individual and safe and healthy working environments, also through the diffusion of a culture of safety and risk awareness, promoting responsible behavior by all in compliance with company procedures and the provisions of the law.

With this in mind, each employee is called upon to contribute to and maintain the safety of the work environment in which he or she operates and to behave responsibly in order to protect himself or herself and others.

Due to the activity carried out, the Company takes into utmost consideration the protection of the environment, pursuing the improvement of the environmental conditions of the community in which it operates.

3.12 Continuous improvement and quality of services provided

All company activities and behaviors are oriented to the maximum attention towards customers, having as objective the achievement of optimal quality standards in view of their best satisfaction, and this also in relation to after-sales processes.

3.13 Protection of Competition

E-GAP observes the current rules on competition and refrains from encouraging and / or putting in place behaviors that may integrate forms of unfair competition.

E-GAP and the Recipients are committed to contribute to a healthy and fair system of competition in order to continuously improve and develop the business activities.

4. Unethical Behavior

Unethical conduct in the provision of Services or in the performance of work activities may compromise the relationship of trust between the Company and its stakeholders. The conduct of Recipients, whether individuals or organizations, who violate the fundamental principles enshrined in this Code, with the specific aim of taking advantage of the benefits deriving from the collaboration of others, exploiting positions of strength, and abusing the fundamental relationship of intuitu personae, constitutes unethical conduct and is therefore hostile and repudiated by the Company.

5. Customer Relationships

E-GAP unifies its conduct in dealing with customers to principles of legality, transparency, reliability, fairness, sustainability, responsibility, and quality. In particular, customer satisfaction is one of the primary objectives that E-GAP aims: kindness and attention in relationships, clarity, and completeness in communications, are the tools to achieve the goal.

E-GAP, in fact, is committed to ensuring high and adequate standards of quality and safety of the services offered, and to use methods of verification and measurement of the level of customer satisfaction to set corrective actions and improvements.

In order to build a long-lasting relationship with customers E-GAP prepares:

  • the identification of needs and interests, as well as their satisfaction through products and services that meet expectations;
  • the care of the relationship;
  • innovation and continuous improvement of the offer.

The Company is also committed to always give feedback to suggestions and complaints, using appropriate and timely communication systems.

6.  Relations with Suppliers, Business Partners and Financial Counterparties

E-GAP bases its conduct in relations with suppliers, partners, and financial counterparts on principles of clarity, equality and loyalty. It also entertains relationships exclusively with counterparts with the necessary ethical values, integrity, and independence.

In fact, each recipient is required to

•observe and comply, in supply and partnership relations, with the applicable legal provisions and the contractual conditions laid down;
• obtain the collaboration of suppliers in ensuring that customer requirements are met in terms of quality, cost and delivery times of goods or services;
• to reach, with suppliers, partners and counterparties, the stipulation of contracts or agreements on mutually favorable and advantageous conditions.

7. Relations with Managers, Employees and Personnel Management

Respect for the person is considered a pre-eminent value for E-GAP, together with the professional development and the complex of relational, intellectual, organizational, and technical skills of each manager and employee. The search and selection of personnel is carried out solely on the basis of criteria of merit, objectivity, and transparency, ensuring equal opportunities and avoiding any form of favoritism and discrimination. The hirings take place with a regular work contract in full respect of the law and of the eventual CCNL applied, favoring the insertion of the worker in the work environment.

E-GAP implements an integrated system of management and development of human resources, which allows to offer to all staff, under equal conditions, the same opportunities for improvement and growth. The essential prerequisite for the assignment of positions of responsibility within the corporate organization and for career progression is the evaluation of skills and value expressed, the results obtained, as well as the potential possessed in close and consistent correlation with the current and future needs of the Company.

8. Relations with Public Administration and Authorities

The relations of E-GAP with the Public Administration are based on maximum transparency, correctness, and legality. In particular, E-GAP entertains, in compliance with the roles and functions assigned according to the law, the necessary relations with the European, the State and local Administrations, based on a spirit of collaboration.
Relations with officials of public institutions are limited to the company functions in charge and regularly authorized in compliance with the strictest observance of the laws and regulations in force, including all the rules on accreditation, and cannot in any way compromise the integrity and reputation of the Company.

E-GAP acts in compliance with the law and promotes, within the limits of its competence, the proper administration of justice. In carrying out its activities, E-GAP collaborates with the representatives of the Authority and any Public Official who has inspection powers, providing all the information requested, in a complete, correct, adequate and timely manner.

In relations with local, national, community and international institutions, E-GAP undertakes to:

  • establish, without any kind of discrimination or affiliation, stable channels of communication with all the institutional interlocutors involved during the implementation of its activities;
  • represent its interests and positions in a transparent, rigorous and consistent manner, avoiding collusive attitudes;
  • act in compliance with the principles defined by the Code in carrying out its activities, not exerting direct or indirect pressure on managers or representatives of the institutions, in order to obtain favors or advantages.

9. Health, Safety and Environment

E-GAP, as part of its activities, is committed to disseminate and consolidate the culture of safety, developing risk awareness and using all necessary resources to ensure the safety and health of employees, contractors, and communities in which it operates.
The staff of E-GAP, as part of their duties, must participate in risk prevention, environmental protection, health and safety of themselves, colleagues and third parties.

E-GAP recognizes the need to contribute to the protection of the environment through its activities, as well as through compliance with current legislation and the constant monitoring of its processes and activities. E-GAP is committed, therefore, to promote greater compatibility and environmental sustainability of its products and services, as well as warehouses and offices, aiming to respect the environment, advanced and efficient technologies, applicable to the entire life cycle of products in respect of its peculiarities. The Company aims at an appropriate use of natural resources, ensuring constant attention to the reduction of their environmental impact, in compliance with laws and regulations.

E-GAP, in the exercise of its activities, adheres to the fundamental principles and criteria of respect and protection of the environment, which it considers a primary asset and is committed to safeguard seeking in all its activities a balance between economic initiatives and essential environmental needs, in consideration of the rights of present and future generations.
Furthermore, in order to implement a concrete environmental policy, the Company is committed to raising the awareness of the community on environmental issues, increasing the sense of responsibility towards the protection of the environment in particular by (i) contributing to the creation and dissemination of a culture of sustainable energy use, actively contributing to the energy transition (ii) promoting a responsible use of energy while respecting the environment (iii) safeguarding environmental diversity and integration.

10. Privacy Policy

E-GAP complies with the requirements regarding the confidentiality of personal data pursuant to Regulation (EU) No. 2016/679 (on the protection of individuals with regard to the processing of personal data and on the free movement of such data, better known as “GDPR”).

With particular regard to the processing of personal data of workers, E-GAP undertakes to take all measures reasonably necessary to inform each manager, employee, external collaborator, or customer about the nature of personal data processed by the Company, the methods of treatment, the areas of communication and, in general, any data relating to his person to ensure that Personal Data are treated safely and in accordance with the Privacy Policy.

E-GAP has designed all the systems through which Personal Data are collected, stored, and processed according to the highest standards of security, to ensure respect for privacy.

All persons who will participate in the process of treatment of the Data on behalf of the Company have been specifically trained, instructed, and appointed to ensure respect for privacy.

11. Violations and Consequences

The observance of the rules of conduct contained in the Code must be considered an essential part of the contractual obligations foreseen for employees of the Company, for managers, and for external collaborators of the same. A serious breach of the Code constitutes a breach of the obligations arising from the employment relationship.

With reference to internal subjects, the violation of the provisions for conduct that does not comply with this Code constitutes a breach of the obligations of the employment relationship and/or a disciplinary offence, in accordance with the procedures provided for by law, and the provisions contained in the employment contracts.
Consequently, sanctions may be imposed – according to the criterion of proportionality, based on the seriousness and intentionality of the infringement committed, also considering any repetition of the breaches and/or violations committed. The Company has also defined the methods of dispute and cross-examination in order to ascertain the violations and the related responsibilities.
The application of the disciplinary system is independent with respect to the conduct and outcome of any criminal proceedings initiated before the competent judicial authority and in compliance with labour law provisions, with all legal consequences.

The provisions of this Code also apply to any temporary workers who will be required to comply with its precepts. Violations of the Code by the same are sanctioned with disciplinary measures adopted against them by the respective employment agencies that are required to do so by virtue of the contractual commitment with E-GAP, according to the specific contractual provisions signed from time to time.

Compliance with the Principles of this Code of Ethics is also an essential part of the contractual obligations assumed by those who have business relationships with the Company, with the result that any violation will constitute a breach of contract with all the consequences of the law with regard to the termination of the contract and compensation for damages.

12. Adoption and modification of the Code of Ethics

This Code of Ethics adopted on August 3, 2021, by the Board of Directors and is amendable only by the Board of Directors.
At least once a year, on the occasion of the approval of the Company’s draft financial statements, the Board of Directors shall discuss the effectiveness of this Code, in relation to the circumstances and needs, and may consider making any amendments or additions that are appropriate and/or essential for the proper conduct of the Company’s business.



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