Code of Ethics and Model 231

With Legislative Decree no. 231 of June 8, 2001, titled "Regulation of the administrative liability of legal persons, companies, and associations, including those without legal personality," a regime of liability for companies was introduced into our legal system. This liability is classified as administrative but is essentially of a criminal nature, adding to the responsibility of the natural person (director, employee, consultant, collaborator, etc.) who materially commits certain unlawful acts or facts if they are carried out in the interest or to the advantage of the Company.

This Decree provides a specific form of exemption from liability if the Company adopts an organization, management, and control model (the "Model 231"), of which the Code of Ethics is an integral part.

With this information, U. Del Corona & Scardigli S.r.l. informs that, by resolution of the Board of Directors on December 28, 2018, it adopted its own Model 231 and simultaneously appointed a Supervisory Body responsible for monitoring the functioning and compliance with the said Model and ensuring its relevant updating.

The Model is periodically reviewed and updated to ensure its continuous compliance with the provisions of Decree 231 and any changed conditions in the Company's operational structure.

The Model consists of the Code of Ethics, a General Part, and a Special Part, the latter accompanied by control protocols that focus on the identified crime risks in the Model.

In the General Part, which can be downloaded from this page along with the Code of Ethics, the salient aspects of the Model 231 adopted by the Company are indicated, including:

• Objectives and purposes pursued with the adoption of the Model
• Fundamental elements of the Model
• Code of Ethics and disciplinary system
• Potential risk areas for committing crimes
• Recipients of the Model
• Supervisory Body
• Involvement of personnel in the application of the Model and related training and education
• Sanctioning and disciplinary system in case of violations of the Model

Code of Ethics