MODEL 231 AND CODE OF ETHICS

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CODE OF ETHICS

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Legislative Decree 231/2001 (the “Decree”) introduced into the Italian legal system the principle of “administrative liability” of companies.

Sinloc has always pursued its objectives in compliance with universal values of lawfulness, trustworthiness, fairness and transparency. Because of this, in order to prevent the crimes covered by the Decree, by resolution of the Board of Directors of 16 November 2012, SINLOC has adopted:

an Organization, Management and Control Model (“the Model”) which requires that procedures and protocols are observed by all company personnel and by other parties with whom Sinloc interacts (corporate bodies, employees, customers, suppliers, collaborators, partners, and all those who cooperate in any way to achieve the corporate objectives);

a “Code of Ethics”, which sets out the ethical standards and “business principles” that have always characterized Sinloc and which, therefore, Sinloc intends to use as guidelines for its business activities in compliance with legislation in force.

In compliance with the provisions of the Decree, the Organizational Model and the Code of Ethics, the Board of Sinloc has appointed a Supervisory Body (SB), which is entrusted with the task of supervising operations, compliance, adequacy, maintenance and need for updates of the Organizational Model, as well as ensuring that it is updated.

To report information or facts relating to crimes committed that are relevant to the Decree, or practices potentially not in line with the Code of Ethics, please write to the dedicated e-mail address odv231@sinloc.com.