ORGANISATION MODEL UNDER LEGISLATIVE DECREE No. 231/01

Following a resolution of the Board of Directors, we have adopted the Organisation, Management and Control Model (“Model 231”) as required by Legislative Decree No. 231 of 8 June 2001, “Regulation on the Administrative Liability of Legal Persons, Companies and Associations, including those without Legal Personality”. The Model 231 and the principles contained therein are addressed to all members of the company boards, to all independent contractors, employees and, more generally, to all persons who engage in work for our company and any other natural or legal person with whom we come into contact in the course of business dealings.

SUPERVISORY BOARD

A Supervisory Board (SB), appointed by the Board of Directors, has been created to supervise the operation of and compliance with the Model 231. The Supervisory Board is single-member in nature and currently consists of: Giacomo Cardani, Attorney-at-law

CODE OF ETHICS

We have enacted a Code of Ethics  that sets out ethical commitments and responsibilities in the conduct of business and professional practices. This Code also specifies the set of values and principles, as well as the lines of conduct, to be followed by the directors, by all persons tied by employment agreements with our company and, in general, all those who work for us, whatever the connection.

WHISTLEBLOWING

Any person who becomes aware of violations of the principles of the Model 231 and/or the Code of Ethics is required to promptly report them via the email address odv@lascalaw.com or by ordinary mail to the attention of the Supervisory Board c/o La Scala Società tra Avvocati, Via Correggio 43, 20149 Milan.