231 Model

We have always been committed to combining the need to optimise economic growth with the fundamental principles of business ethics. In addition to issuing and adopting the Group's Code of Ethics and Anticorruption Policy, we have implemented an Organisational, Management and Control Model since 2003; its aim is to establish a structured system of rules and controls to be complied with in order to prevent the offences set out in Legislative Decree 231/2001.

The Organisational, Management and Control Model has been prepared in accordance with the nature and characteristics of the Company's activities and its organisational structure and, therefore, highlights, refines and integrates the specific tools aimed at planning the formation and implementation of decisions and carrying out controls on the Company's activities, and, more specifically:

the organisational system;
governance instruments;
the internal control and risk management system.

The Model we adopted was last updated in December 2023, taking into account the best practices on the subject and the provisions of the new Confindustria Guidelines, and represents the Company's constant commitment to operate in full transparency and sense of responsibility towards all stakeholders.

The Supervisory Board

The Supervisory Board is responsible for verifying the adequacy and effective implementation of the 231 Model, in order to prevent the commission of the offences referred to in Legislative Decree 231/2001.

Enrico Giarda

External member

Enrica Marra

Chief Internal Audit, Risk & Compliance Officer

Graziano Visentin

External member

Attachments

Any violation or suspected violation of the 231/01 Model and/or any other information relating to the implementation of the Model may be reported through the special digital "WHISTLEBLOWING" CHANNEL" ; reports received through this channel are managed by the Whistleblowing Team, in accordance with the provisions of the "WHISTLEBLOWING MANAGEMENT" PROCEDURE.

A similar procedure is applicable to the reports received through the two additional channels provided for by the "Whistleblowing Management" Procedure:

By e-mail: SEGNALAZIONI.MUNDYS@MUNDYS.COM;
by ordinary mail to the attention of: Mundys, Comitato Segnalazioni Mundys, Piazza San Silvestro 8, 00187 Rome.