CODE OF CONDUCT

Fincantieri operates within a framework of fair competition, with honesty, integrity, propriety and good faith, respecting the legitimate interests of shareholders, employees, customers, business and financial partners, as well as the communities and local areas where it conducts its activities.

In particular, it promotes Social Responsibility—understood as the integration of social and environmental concerns into its strategic vision—providing information on related actions in its periodic reports.

Everyone working at Fincantieri, without distinction or exception, is committed to observing and ensuring compliance with these principles within the scope of their functions and responsibilities. Under no circumstances can the belief of acting in the interest or to the advantage of the Company justify conduct that conflicts with these principles.

Given the complexity of the situations in which Fincantieri operates, it is important to clearly reaffirm the set of values that the Group recognizes, accepts and shares, as well as the responsibilities it assumes both internally and externally. For this reason, the Code of Conduct (“Code”) has been drawn up, and compliance with it by all those operating within the Company is fundamental to the proper functioning, reliability and reputation of the Group—factors that constitute a decisive asset for the success of the enterprise.

Employees, in addition to fulfilling their general duties of loyalty, fidelity, propriety, and performing their employment contract in good faith, must refrain from engaging in activities that compete with those of the Group, comply with company rules, and adhere to the provisions of this Code. Relationships among employees, at all levels, must be based on transparency, propriety, loyalty and mutual respect.

Directors and all those working in the Company are required to be familiar with the Code, actively contribute to its implementation, and report any shortcomings or violations.

Fincantieri is committed to facilitating and promoting awareness of the Code among employees and encouraging their constructive input regarding its contents. The Code is communicated to all parties with whom Fincantieri maintains business relations.

Fincantieri monitors compliance with the Code by providing appropriate tools for information, prevention, and control and ensuring transparency in operations and conduct. The responsibility for verifying the implementation and application of the Code of Conduct lies with the Board of Directors and Company Management, who may propose additions or amendments to its contents.

Any conduct contrary to the letter and spirit of the Code will be sanctioned in accordance with the provisions of the Code itself. The principles outlined in the Code of Conduct may be supported by specific directives, regulations or internal procedures designed to make its application more concrete and precise.