ANTI-CORRUPTION POLICY AND FUNCTION

In the process of continuous evolution and improvement of the Company’s anti-corruption system, in 2020 the UNI ISO 37001 certification for Anti-Bribery Management Systems was obtained, and the Compliance Function for the prevention of corruption was established, with responsibility assigned to the Head of the Group Compliance, Anti-Corruption and Model 231 Function.

The primary task is to implement and manage the company’s anti-corruption program, which includes the following responsibilities:

Ensuring monitoring of legislation and case law on anti-corruption as well as the evolution of leading practices at national and international level;

Supervising the design and implementation of the Anti-Corruption Management System in accordance with applicable regulations and the requirements of the UNI ISO 37001 standard;

Coordinating the process of identifying and assessing risks (so-called risk assessment) in the area of anti-corruption and identifying controls to safeguard against such risks;

Conducting audits on the implementation of the Anti-Corruption Management System;

Promoting and supporting the relevant company functions in defining and implementing training programs on Anti-Corruption and the operation of the related Management System;

Providing consulting support, specialist assistance and guidance to Company employees and other Group companies regarding the Anti-Corruption Management System and issues related to corruption;

Managing the Company’s reporting system and supporting the process of analyzing and evaluating reports of violations and/or offenses or, in any case, conduct not in line with the rules of conduct adopted by the Company regarding anti-corruption activities.

In addition, periodic information on the performance of the Anti-Corruption Management System is provided to the Board of Directors, the Chief Executive Officer, and other Corporate Bodies, as well as ad hoc information flows to the same parties in the event that any issue or suspicion needs to be raised in relation to acts of corruption or the Anti-Corruption Management System.

In the process of continuous evolution and improvement of the Company’s anti-corruption system, in 2020 the UNI ISO 37001 certification for Anti-Bribery Management Systems was obtained, and the Compliance Function for the prevention of corruption was established, with responsibility assigned to the Head of the Group Compliance, Anti-Corruption and Model 231 Function.

The primary task is to implement and manage the company’s anti-corruption program, which includes the following responsibilities:

Ensuring monitoring of legislation and case law on anti-corruption as well as the evolution of leading practices at national and international level;

Supervising the design and implementation of the Anti-Corruption Management System in accordance with applicable regulations and the requirements of the UNI ISO 37001 standard;

Coordinating the process of identifying and assessing risks (so-called risk assessment) in the area of anti-corruption and identifying controls to safeguard against such risks;

Conducting audits on the implementation of the Anti-Corruption Management System;

Promoting and supporting the relevant company functions in defining and implementing training programs on Anti-Corruption and the operation of the related Management System;

Providing consulting support, specialist assistance and guidance to Company employees and other Group companies regarding the Anti-Corruption Management System and issues related to corruption;

Managing the Company’s reporting system and supporting the process of analyzing and evaluating reports of violations and/or offenses or, in any case, conduct not in line with the rules of conduct adopted by the Company regarding anti-corruption activities.

In addition, periodic information on the performance of the Anti-Corruption Management System is provided to the Board of Directors, the Chief Executive Officer, and other Corporate Bodies, as well as ad hoc information flows to the same parties in the event that any issue or suspicion needs to be raised in relation to acts of corruption or the Anti-Corruption Management System.