TRAINING

For Fincantieri, the primary objective is to ensure the continuous dissemination of rules for ethical business management in compliance with current laws and regulations. In this context, particular importance is given to:

the System of safeguards provided by Legislative Decree 231/01, whose knowledge must be promoted and shared at all levels of the Company's organization;

the Anti-Corruption Management System adopted by the Company in accordance with the requirements of UNI ISO 37001:2016 for the prevention of corruption.

To this end, Fincantieri has structured a training program that allows employees to be accompanied and supported throughout their professional development within the Company, to promote increasing awareness of compliance with the Organizational, Management and Control Model pursuant to Legislative Decree 231/01 as well as the Anti-Corruption Management System. The training paths are differentiated to allow targeted dissemination of topics, taking into account the role and responsibilities of those involved.

The training plan regarding the 231 safeguard system includes the delivery of the following modules:

"General part 231", intended for all employees and trainees, illustrates the principle of entity responsibility with the aim of disseminating and sharing at all levels the measures put in place by Fincantieri to prevent the commission of predicate offenses by individuals who may commit the Company;

"Special parts 231", intended for all employees and trainees, provide an in-depth analysis of certain types of offenses of particular relevance to Fincantieri, specifically:

• offenses against Public Administration and corporate offenses;
• offenses related to health and safety in the workplace and environmental offenses;
• offenses against individual personality and tax offenses.

The training plan regarding the Anti-Corruption Management System includes two modules:

• "General part", intended for all employees and trainees, illustrates the characteristics of the Anti-Corruption Management System, control principles, management and control tools and procedures and the Whistleblowing reporting system;
• "Specific part", intended for the Company's Attorneys, provides an in-depth analysis of issues related to corruption risk and the damage that may result both for the Company and for those involved, the circumstances in which corruption may occur, and how to recognize and manage the main risk indicators, illustrating some exemplary cases.

In order to ensure constant learning and understanding of the topics covered by Legislative Decree 231 and the Anti-Corruption Management System, periodic reminders (every three years) are provided, as well as ad hoc updates in relation to any legislative interventions on the reference regulations or changes in the risk profile.