Code of Ethics, Model 231, and Whistleblowing

The company prevents risks arising from liability under Legislative Decree No. 231/2001 through the adoption and effective implementation of a specific organizational, management, and control model (‘the Model’).

The Model is a structured and organized system of guidelines and control activities, to be carried out also and mainly preventively, and designed not to be violated except by fraudulently evading its provisions.

To this end, the organizational, management, and control Model:

identifies sensitive processes,

defines specific protocols for decision-making related to sensitive activities,

identifies methods for managing financial resources suitable for preventing the commission of offenses,

introduces a disciplinary system in case of violations of the Model,

establishes the structure and functioning of a Supervisory Board.

The Group Code of Ethics is an integral and fundamental part of the Model.

The Model, adopted in October 2019 is periodically updated to incorporate organizational and process changes, as well as new instances of misconduct that have progressively expanded the scope of application of Legislative Decree No.231/2001.

The latest update of the model was approved by the Board of Directors on July 9, 2020.