1. PREMISE

Aniasi Leonetti Srl (hereafter the “Company”) has prepared, in order to clearly and transparently define the set of values by which the Company is inspired in order to achieve its objectives, this Code of Ethics, the observance of which is essential for the correct functioning, reliability, reputation and image of the Company, which are the foundations for both the success and current and future development of the organization.

Company activities must therefore comply with the principles expressed in this Code of Ethics.

Aniasi Leonetti Srl recognizes the importance of ethical and social responsibility in the conduct of business and corporate activities and is committed to respecting the legitimate interests of its stakeholders and the communities in which it operates. At the same time, it requires all Company employees and all those who cooperate in carrying out Company business to comply with the Company rules and guidelines established in this Code.

2. MISSION AND ETHICAL VISION

The Company intends to maintain and develop a relationship of trust with its stakeholders and pursue its objectives by seeking the best balance among the interests involved, in compliance with all legal provisions and the principles of honesty, impartiality, reliability, loyalty, integrity, transparency and good faith.

3. THE CODE

The Company considers it appropriate and necessary to adopt and issue its own code of conduct in order to outline the values with which all directors, employees and collaborators in various capacities must comply, accepting responsibilities, structures, roles and rules, the violation of which, even in cases where no corporate responsibility towards third parties exists, requires the assumption of personal responsibility both internally to, and externally of, the company.

The knowledge and observance of the Code of Ethics by all those who operate on behalf of the Company are therefore primary conditions for the transparency and reputation of the Company.

In addition, this Code of Ethics is brought to the attention of all those with whom the Company has business relationships.

Verification of the content and principles of the Code of Ethics and its application is the responsibility of company Directors and management, who may also act as agents for eventual integrative proposals or modification to its contents. It is also the responsibility of Company Directors and management to update the Code of Ethics in order to adapt it to any relevant legislation and the evolution of civil sensibilities.

Stakeholders are intended as all those with shared interests for a company such as employees, clients, suppliers and institutions.

4. FIELDS OF APPLICATION OF THE CODE

This Code of Ethics applies to all services performed by Aniasi Leonetti Srl.

The principles and provisions of the Code of Ethics are binding for directors, employees and all those who work for the Company on the basis of a contractual relationship, whether permanent or temporary. All aforementioned subjects are collectively referred to below as “beneficiaries”.

The Company carries out its business activities with the utmost integrity and a refusal to compromise. Each employee of the Company, including Directors, managers and all staff, have a duty to comply with all applicable laws and regulations, as well as to comply with the highest principles of business ethics. No employee may, for any reason, engage in illegal or unethical activities, or facilitate others in doing so.

Company employees are required to comply with the Code as well as the policies and guidelines that derive from it.

The Company undertakes to disclose the Code of Ethics to beneficiaries through specific communication activities.

In order to ensure an adequate understanding of the Code of Ethics, periodic communication plans are to be prepared and implemented in order to promote knowledge of the principles and ethical standards contained within the Code.

5. PRINCIPLES AND FRAMEWORK OF REFERENCE

5.1 ACTING WITHIN THE LAW

The Company recognizes compliance with the laws and regulations in force in all those the countries in which it operates as an essential principle.

5.2 HONESTY AND INTEGRITY

Company staff undertake to act loyally, honestly, ethically and in compliance with relative laws in force, in all commercial relations carried out on behalf of the Company, including relations with clients, suppliers, competitors and employees of the Company itself.

No employee is authorized to gain an unfair advantage from another person through manipulation, concealment, illicit use of privileged or confidential information, misrepresentation of essential facts or any other unfair practices.

5.3 THE CENTRALITY OF THE INDIVIDUAL

The Company promotes respect for the physical and cultural integrity of the individual.

The Company guarantees the well-being of all individuals operating within it.

The Company does not tolerate requests or threats aimed at inducing individuals to act against the law or the Code of Ethics, or to adopt behaviour that is harmful to the moral and personal beliefs and preferences of each or any individual.

The Company supports and respects human rights in accordance with the UN Universal Declaration of Human Rights.

5.4 IMPARTIALITY AND EQUAL OPPORTUNITIES

The Company undertakes to avoid any discrimination based on age, sex, sexuality, health status, race, nationality, political opinions and religious beliefs, in all decisions that affect relations with its stakeholders.

5.5 TRANSPARENCY AND ACCURACY OF INFORMATION

The Company undertakes to clearly and transparently inform all stakeholders of episodes that may have an influence on the quality of the activities carried out, without favouring any interest group or individual, through the functions delegated for this purpose.

5.6 TRUST AND COLLABORATION

Relations with stakeholders must, at all levels, see criteria and conduct to be based on loyalty, honesty, collaboration and mutual respect through constant and transparent dialogue. This is the only way to guarantee the continuity of relationships of trust and collaboration for the mutual benefit and sustainable growth of the values being developed.

Specifically, the belief of acting in some way for the benefit of the company does not justify the adoption of behaviour that conflicts with the aforementioned principles. All those who work for the Company, without distinctions or exceptions, are therefore committed to observing and enforcing these principles in the context of their functions and responsibilities. Such commitment is justified and requires that any subject with whom the Company has relations of any kind or in any capacity act towards it according to the rules and methods inspired by these same values.

5.7 ACCOUNTANCY RECORDING

Accuracy and integrity in recording Company accounts are of primary importance for the success of the Company. Personnel are required to comply with the following indications concerning Company financial documentation.

Accounting principles: Personnel are required to comply with generally accepted accounting principles where applicable and all regulatory requirements that relate to such principles. Staff are required to perform all transactions in accordance with Company policies and procedures.

Unregistered funds: All transactions and agreements, assets, liabilities, income and expenses, must be recorded and described in Company accountancy recording documentation.

False entries: Personnel are not authorized to intentionally or for any reason make false or misleading entries in Company accountancy recording documentation nor contribute to, or facilitate, such conduct.

Recognition of income and outgoings: Both income and outgoings must be accounted for by applying the provisions of accounting principles and the laws in force. In no case may entries by registered early (prior to the fiscal period) or delayed (subsequent to the fiscal period) or manipulated in any way that entails adjustments to an accurate accounting and recording system.

Authorization: In order to be granted access to bank account funds or make bank transfers, staff must be authorized according to Company cash management policies. Personnel may use funds or other property owned by the Company only via prior authorization and exclusively for legitimate business purposes.

Payments: Personnel cannot make any type of payment in the name of the Company without adequate supporting documentation, or for any purpose other than that described in the relative supporting documentation.

Monitoring and Control: Any payment for travel, gifts or hospitality must be authorized by management. Such costs must always be documented by the head of internal auditing who must have documented evidence of auditing activities. During internal audits, the company must ensure detailed control of all financial aspects for the purpose of preventing bribery.

5.8 CONFIDENTIALITY OF INFORMATION

Personnel have an obligation to safeguard non-public Company information.

All employees are required to maintain confidentiality regarding information entrusted to them by the Company or its clients, except in cases where the disclosure of such information is authorized or imposed by law. Confidential information includes all unpublished information which, if disclosed, could prove useful to competitors or harm the company or its clients. Some examples of this information include, although are not limited to: commercial information, projects, practices, client contacts, potential clients, pricing structures, financial information, manuals, methodologies and management philosophies regarding Company business. Confidential information, as well as information relating to other employees, refers to, although is not limited to: compensation, performance assessments, disciplinary action or investigation, medical information, addresses and personal telephone numbers.

Company personnel are prohibited (a) from profiting personally from opportunities that arise from the use of Company property, information or status, (b) from using Company property, information or status to their personal advantage and (c) competing with the Company.

5.9 PREVENTION OF CONFLICTS OF INTEREST

Staff will do their utmost to avoid any activity that may affect their ability to act in the interest of the Company or that may create obstacles to the performance of their work in an objective and effective way.

Any corporate gifts, whether offered or received by staff, must be intended to establish integral and solid working relationships, and not for the obtaining of illicit advantages from clients or suppliers. Staff must comply with at least the following procedures:

• No Company employee shall knowingly initiate a transaction with any company or person or in any partnership role (with the exception of their capacity as an employee for the benefit of the Company) which may give rise to a real or apparent conflict of interest between the employee and the Company.

• Employees cannot hold public office within public bodies or have relatives who operate within those public bodies operating within the same fields as the Company.

• In relations with public bodies, all Company staff are prohibited from establishing confidential or personal relationships.

• The Company promotes exclusively formal meetings with officials of public bodies. Any meeting held at a public body must be communicated to management.

5.10 PROTECTION AND PERSONAL USE OF COMPANY PROPERTY

Company staff are required to protect Company assets and ensure that efficient use is made of them. Theft, negligence and waste directly affect the net profit of the Company. Anything owned by the Company such as office supplies, computers, office space and materials, must be used exclusively for the legitimate purposes of the business, although personal use may occasionally be permitted.

5.11 CLIENTS

The style of behaviour towards clients is based on openness, respect and courtesy, with a view to collaborative and highly professional relationships.

Consistent with the principles of impartiality and equal opportunities, Aniasi Leonetti Srl undertakes not to arbitrarily discriminate against its clients, to provide high quality services that meet the client’s reasonable expectations, protect their safety and security and to be truthful in communications, whether commercial or otherwise.

Aniasi Leonetti Srl operates with clients in compliance with the following specific principles for the purpose of ethically appropriate behaviour:

• Accuracy and honesty of information;

• All information on services must be provided in a clear, honest and balanced way;

• All communications addressed to clients are written in clear language, in the simplest possible way and with an easy-to-read graphic form, so as to facilitate their immediate understanding;

• Client Satisfaction monitoring.

Aniasi Leonetti S.r.l. constantly monitors the quality of services rendered and levels of client satisfaction. Aniasi Leonetti S.r.l. pays particular attention to client complaints and considers their correct, transparent and balanced management as essential for promoting greater understanding between the parties and the eventual settling of disputes.

Complaints are also analysed in order to understand potential causes that generated irregularities, inefficiency or misunderstanding and to promote the improvement of the quality of products and services.

5.12 SUPPLIERS

Purchasing processes are based on the identification of maximum competitive advantage and the granting of equal opportunities, loyalty and impartiality for each supplier.

The appointment of suppliers and the identification of purchase conditions are based on an objective assessment of quality, price and ability to provide and guarantee services of a satisfactory level. In detail, employees cannot:

• receive any form of payment from any party in exchange for the execution of an action of their office or contrary to official duties;

• undergo any form of conditioning by third parties unrelated to, and unauthorized by, the Company, for the taking of decisions and/or the execution of tasks relating to their work.

An employee who receives gifts, or any other form of benefit, not directly attributable to normal civil relationships must take any appropriate initiative in order to refuse a gift, or other form of benefit as well as informing their line manager.

5.13 RELATIONSHIPS WITH PUBLIC BODIES

The relationship of the Company with public bodies will be governed only by the corporate functions for which it has been delegated.

In relations with employees and representatives of public bodies, members of the corporate organization of the Company must behave based on the principles of transparency, honesty and fairness.

Compliance is required with the provisions of the Code of Ethics regarding conflicts of interest, with particular reference to corporate procedures for the authorization of gifts.

Staff will immediately notify Company Management and the Head of Anti-Bribery of any attempt at extortion made against them by those within public bodies (The Italian Inland Revenue or GdF – Financial Law Enforcement Agency) such as public officials or persons managing public services.

In the event that the Company assigns a representative role to a third party in order to be represented in dealings with a public body, this third party will be subject to the application of the Code of Ethics, with particular reference to the rules outlined in matters of conflicts of interest, in addition to those directives provided upon the assignment of the role.

5.14 PERSONAL RESPONSIBILITY

Company employees are to assume personal responsibility which embodies and conforms to ethical behaviour. All staff are responsible for leading by example and ensuring that all employees read the Code of Ethics and have the opportunity to discuss its practical application. Internal staff are required to examine the Code of Ethics at least once a year and whenever significant changes are deemed necessary. Everyone has a duty to monitor and detect situations that may indicate illegal or anti-ethical behaviour and to act in an adequate and timely manner in order to prevent improper conduct.

6. PROVISION OF SANCTIONS

Compliance with the rules of this Code of Ethics must be considered a fundamental part of the contractual obligations of any employee pursuant to and for the purposes of Art. 2104 of the Civil Code. Violations of the rules of the Code of Ethics may constitute non-fulfilment of the primary obligations of the employment relationship or as a disciplinary offence, in compliance with the procedures outlined in Art. 7 of the Employee Statute with full legal implications, including in terms of the preservation of working relationships, and may result in compensation for damages deriving from such incidents.

Compliance with the Code of Ethics must be considered an essential part of contractual obligations assumed by non-subordinate collaborators and consultants and/or subjects involved in business relations with the Company. The violation of the rules of the Code of Ethics may constitute a breach of contractual obligations, with full legal implications, including in terms of the termination of contractual obligations or agreements and may result in compensation for damages deriving from such incidents.

7. FINAL PROVISIONS

This Code of Ethics is recognized as company practice and has been approved by the Company Directors. Any variation and/or integration of this Code is to be approved by the Board of Directors and promptly communicated to beneficiaries.

1. SCOPE

The purpose of this document is to outline the general anti-bribery principles as defined by Aniasi Leonetti Srl in order to develop an efficient and adequate Anti-Bribery Management System.

The Anti-Bribery Policy represents expectations of the behavioural objectives established by Aniasi Leonetti Srl for all its employees and business partners.

For this reason, all company staff and business associates are invited to read this document carefully, given that it is the responsibility of everyone to prevent, detect and report any form of bribery.

For this reason, appropriate confidential channels have been set up for the reporting of any suspicion of bribery.

2. DESCRIPTION

Aniasi Leonetti Srl considers the primary objective of anti-bribery to be the prevention, tracing and tackling of bribery. Aniasi Leonetti Srl does not acknowledge exceptions to the prescriptions and prohibitions set out within this Policy. The belief of having acted in the interests of the organization does not, in any way, justify the adoption of behaviour contrary to these aforementioned principles.

The principles and rules referred to in the present Policy view as unlawful for staff, the Company, Business Partners and any individual exercising an activity in favour of or on behalf of the Company, the offer, payment or acceptance, directly or indirectly, of money of other benefits for the purposes of obtaining or maintaining business or securing an unjust advantage in relation to business activities.

Useful definitions include:

1. Bribery: The offer, promise, provision, acceptance or request of an undue advantage of any value (which may be economic or non), directly or indirectly, and regardless of location, violating the current law, as an incentive or reward for a person to act or omit actions in connection with the performance of that person’s duties.

2. Organization: Person or group of people establishing their own functions over areas of responsibility, authority and relationships in order to achieve their goals.

3. Requirement: A requirement that is explicit and mandatory.

4. Management System: Set of related or interacting elements of an organization aimed at establishing policies, objectives and processes in order to achieve these objectives. Elements of the system include structure, roles and responsibilities, planning and functioning of the organization.

5. Management: Group of people who, at the highest level, manage and control an organization and hold ultimate responsibility and authority for the organization’s activities, administration and policies.

6. Anti-Bribery compliance function: The person or people with responsibility and authority for the functioning of the Anti-Bribery Management System.

7. Effectiveness: Degree of realization of the planned activities and achievement of the planned results.

8. Policy: Direction and guidelines of an organization, as formally expressed by its top management or its governing body.

9. Objective: Results to be achieved. Objectives are defined by the organization, in line with the Anti-Bribery Policy put in place to achieve specific results.

10. Risk: The effect of uncertainty on objectives, where uncertainty is the state, or partial state, of a lack of information relating to the understanding or knowledge of an event, its consequences or its probability. Risk is often expressed in terms of combining the consequences of an event and the “probability” associated with its occurrence.

11. Availability: Information must be available promptly, when required by company processes, both efficiently and effectively;

12. Process: Set of related or interacting activities that transform inputs into outputs.

13. Monitoring: Establishing the state of a system, process or activity. In order to determine its status, it may be necessary to check, monitor or critically observe.

14. Compliance: Satisfaction of a requirement.

15. Non-compliance: Failure to satisfy a requirement.

16. Corrective action: Action aimed at eliminating the cause of non-conformity and preventing its recurrence.

17. Continuous improvement: Reoccurring performance improvement activities.

18. Staff: Managers, officers, employees, staff or temporary and voluntary workers of the organization. Different types of staff pose different types and degrees of bribery risk and can be treated distinctly in terms of the procedures for assessing the risk of bribery and managing the organizational risk of bribery.

19. Business partner: External party with which the organization has established, or plans to establish, any form of commercial relationship. Business partners include, but are not limited to, customers, buyers, “joint ventures”, joint venture partners, consortium partners, external suppliers, contractors, consultants, subcontractors, vendors, experts, agents, distributors, representatives, intermediaries and investors.

20. Public official: Person who holds legislative, administrative or judicial positions, regardless of whether they derive from appointment, election or succession, or any person who exercises a public function, including those acting on behalf of a public agency or public enterprise, any official or agent of a public organization, national or international, or any candidate for a public office.

21. Third party: Person or entity independent of the organization.

3. FIELD OF APPLICATION

The Aniasi Leonetti Anti-Bribery Policy applies to all internal staff and third parties who collaborate towards the realization of the services offered.

For this reason, the company undertakes to disseminate the information contained within the policy and invite stakeholders to sign a declaration of understanding.

4. DECLARATION OF ANTI-BRIBERY POLICY

The Anti-Bribery Policy of Aniasi Leonetti Srl represents the organization’s commitment to customers and third parties in order to guarantee the prevention of bribery, understood as:

a. Bribery by the organization;

b. Bribery by the staff of the organization, who acts on its behalf or for its benefit;

c. Bribery by business members of the organization, who act on its behalf or for its benefit;

d. Bribery of the organization;

e. Bribery of the organization’s staff in relation to its activities;

f. Bribery of business members of the organization in relation to its activities;

g. Bribery and indirect bribery (e.g. a bribe offered or accepted by or through third parties).

With this document, Aniasi Leonetti Srl undertakes to:

1. Prohibit any corrupt practice: illegitimate favours, collusive behaviour, solicitations, direct and/or through third parties, of personal and professional advantages for either an individual or others;

2. Ensure that the Anti-Bribery Management System, including policies and objectives, is established, implemented, maintained and reviewed in order to adequately address bribery risks within the organization;

3. Ensure that bribery risks and irregularities are promptly recognized and correctly managed through efficient systems of prevention, communication and reaction in order to minimize the impact on the business;

4. Appoint an internal figure who holds authority and independence in order to operate towards the continuous functioning of the Management System;

5. Request, where possible, that business partners who pose a risk of bribery beyond minimal levels are committed to preventing bribery;

6. Be able to terminate relationships with a business partner in the case of bribery committed by the partner, either for their own gain or advantage in relation to transactions, projects, activities or relationships;

7. Not make contributions or donations to political parties or related foundations and associations;

8. Respect the applicable law in force;

9. Guarantee the traceability, availability and correct conservation of documents, IT data and corresponding IT support structures;

10. Promote an appropriate anti-bribery culture within the organization;

11. Communicate the company Anti-Bribery Policy to all staff and business associates, underlining the importance of compliance with the requirements of the Management System;

12. Ensure the application of law 179/2017 (on the act of “whistleblowing”);

13. Ensure continuous improvement to practices;

14. Establish a framework of objectives aimed at measuring and monitoring the absence of bribery;

15. Implement sanctioning systems through internal regulations.

5. SANCTIONS IN CASE OF NON-COMPLIANCE

To ensure the application of the Anti-Bribery Policy, Aniasi Leonetti Srl aims to implement disciplinary measures in line with the CCNNL contract applied to its employees. For all suppliers and customers who demonstrate behaviour that does not comply with this policy, Aniasi Leonetti Srl reserves the right to terminate contractual obligations.

6. RESPONSABILITY FOR ANTI-BRIBERY POLICY

Company Management is responsible for the Anti-Bribery Management System, in line with the evolution of the business and market contexts, evaluating any actions to be taken in the face of events such as:

a. Significant business developments;

b. New threats beyond those already considered through risk analysis processes;

c. Significant cases of bribery;

d. The evolution of the regulatory or legislative framework regarding anti-bribery.

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