Organization and Management Model - Leone Alato

We have adopted an Organization and Management Model that defines behavioral norms and identifies the control principals that must be adopted in order to prevent the risk of committing the crimes set forth in Legislative Decree No. 231 of 2001 and to exclude or limit the resulting administrative responsibilities of the Entity.

In addition, we have appointed a Supervisory Board to oversee the functioning and effective implementation of the Model.

Specifically, the Model, approved by the Board of Directors, consists of a General Part and a Special Part divided into several Sections.

The General Part explains the rationale and principles of Legislative Decree 231/2001, the governance model, the internal control and risk management system, and outlines the components of the Model including the role of the Supervisory Board.

The Sections of Special Part refer to the families of offenses provided for in the Decree and deemed relevant with respect to the sensitive activities carried out by the Company. Also associated with each process in the Sections are the general principles of conduct to which the recipients of the Model must adhere and the specific control safeguards (internal rules) identified in order to prevent the commission of the identified crimes.

The methodology used in the preparation of the Model takes into account the most significant case law pronouncements, best practices in the application of the Decree, and category guidelines.

Composition of the Supervisory Board
Maurizio Bastasin (External Member - Chairman)
Marco Chiesa (Head of Internal Audit Function - Internal Member)
Gabriele Busato (Representative of the Compliance Function - Internal Member)