ETHICAL CODE

ORGANIZATION AND MANAGEMENT MODEL ACCORDING TO LEGISLATIVE DECREE 231/2001

The Legislative Decree 231/2001 introduced a new form of corporate liability for certain types of crimes committed by the directors and employees, as well as by persons acting in the name and on behalf of Vetromeccanica S.r.l.

Vetromeccanica S.r.l., with reference to Legislative Decree 231/2001, has formally established an Organizational Management and Control Model.

The Model thus adopted arises from the need to successfully tackle the complexity of the situations in which the company operates, clearly defining the set of values that inspire it and that it wants to be respected. In no way can the conviction of acting for the benefit of the Company justify the adoption of behaviors in contrast with these principles.

The Vetromeccanica S.r.l. model consists of a “General Part” and a “Special Part” which define the different types of crimes and offenses to be prevented.

The company has also appointed a Supervisory Body with the task of constantly monitoring compliance with the Code of Ethics and the Model by all recipients, and the implementation of the provisions contained therein.

ETHICAL CODE

The Code of Ethics represents, for all those who work with and within Vetromeccanica S.r.l., the tool through which the Company expresses its values and principles of behavior.

All those who have business relationships with, in the name and on behalf of Vetromeccanica S.r.l. are required to contribute to its implementation and the dissemination of the principles formalized therein, so that all relations with external entities can be conducted on the basis of the most absolute correctness, in full compliance with the rights of others, in compliance with the laws in force and the principles of belonging to the company.

At the basis of the Code of Ethics there is a long-term commitment, which supports and lays the foundation for the strategy and economic objectives of industrial development of Vetromeccanica S.r.l.

REPORTING TO THE SUPERVISORY BODY

Vetromeccanica S.r.l. has adopted a management procedure for the reports received from the company’s Supervisory Body, where suitable information channels have been established to allow the communication of any reports on violations of the Code of Ethics and the Organization and Management Model.

Any violation or suspected violation and / or any other information relating to the implementation of the Model or the Code of Ethics, can be reported to the Supervisory Body at the following email address: odv@vetromeccanica.it Or to the postal address: Supervisory Body Vetromeccanica S.r.l. 26, Isolanda Street 43024 Provazzano, Parma (Italy).

REPORTING – WHISTLEBLOWING

Employees, customers and third parties can send, with the maximum guarantee of confidentiality, detailed reports of illegal phenomena and suspicious behavior, of irregularities in the company management, of acts or facts that may constitute a violation of the internal and external rules governing the activity of Vetromeccanica Srl, the principles and rules of conduct contained in the Code of Ethics and in the provisions of Model 231.

The personal data acquired in the reports are treated in full compliance with the current privacy legislation (EU Reg. 2016/679 and Legislative Decree 20 June 2003, n. 196, as amended by Legislative Decree n. 101/2018), with particular regard to the identity of the reporting party.

The Data Controller is Vetromeccanica S.r.l., in the person of its legal representative, with registered office in Via Strada Isolanda 26, 43024 Provazzano, Parma.

With the exception of cases in which liability for slander and defamation is configurable pursuant to the provisions of the criminal code or art. 2043 of the Civil Code and cases in which anonymity is not enforceable by law (eg criminal, tax or administrative investigations, inspections of supervisory bodies) the whistleblower’s identity is protected in every context following the report.

Therefore, subject to the exceptions mentioned above, the identity of the whistleblower cannot be disclosed without his express consent and all personnel involved in any capacity in the management of a report are required to maintain the utmost confidentiality and comply with current legislation. in terms of privacy, considering all information as sensitive.