Organizational Model 231

Pursuant to the national regulations on the “liability of entities for administrative offenses dependent on crimes” contained in the legislative decree of 8 June 2001 n. 231 (hereinafter, “Legislative Decree no. 231 of 2001”) associations – including joint-stock companies – can be held liable, and consequently fined and/or disqualified, in relation to certain crimes committed or attempted in the interest or to the advantage of the Company itself.

Aimuw S.p.A., sensitive to the need to guarantee and promote conditions of correctness and transparency in the conduct of company activities, has positively assessed the opportunity to proceed with the implementation of the Organisational, Management and Control Model pursuant to Legislative Decree no. 231/01 within the Company, which was approved by the Board of Directors on 14 December 2021; at the same time, the Supervisory Body was appointed, with independent powers of initiative and control, which is assigned the task of supervising the functioning and observance of the Model as well as taking care of its updating.

Ethical integrity contributes significantly to the effectiveness of policies and control systems and affects behaviors that could escape the control systems themselves, however sophisticated they may be. It was therefore deemed necessary to disseminate the values ​​at the basis of correct behaviour, in order to stimulate sharing of the same by all the subjects of the corporate structure.

Starting from this premise, the Company has adopted its own Code of Ethics, which summarizes the essence of the Company’s conduct, through a set of values ​​and rules whose respect and observance represent fundamental elements of the company’s business. The Code of Ethics represents a fundamental component of the Model adopted by Aimuw S.p.A.