4.2/ Ethics and responsible business

In order to clearly and transparently define the values and principles guiding the Company, as well as the criteria of conduct regulating its activities, since 2021 Fabbri 1905 has followed the Organisation and Management Model pursuant to Italian Legislative Decree 231/01 and the related Code of Ethics, compliance with which is required of all those who in any capacity contribute to the exercise of the company's activities. All employees have in fact undergone training to learn the model, and in contracts with third parties parties this model is stated among the rules governing the contract to ensure their awareness and acceptance of the rules stated.

According to the provisions of the Model, it is prohibited to engage in, collaborate in or induce conduct which, taken individually or collectively, directly or indirectly constitutes the offences of bribery between private individuals and incitement to bribery between private individuals defined respectively in Article 2635, paragraph 3 and 2635-bis, paragraph 1 of the Italian Civil Code and referred to in Article 25-ter of Italian Legislative Decree 231/2001.

In particular, in managing relations with interlocutors of private companies or entities, it is forbidden to: offering, promising or making undue gifts of money or undue recognition of other benefits;

2 4 distributing free gifts and presents in excess of normal business or courtesy practices. Permitted gifts are always characterised by small value; making unjustified entertainment expenses for purposes other than the mere promotion of the corporate image or for purposes not in accordance with specific corporate procedures;

These prohibitions also extend to third parties (e.g. agents or distributors) acting in the interests of the Company.

From a financial point of view, all inflows and outflows, both those pertaining to ordinary transactions (receipts and payments) and those referring to financial requirements (liquidity, short, medium and long-term financing, risk hedging, etc.) or extraordinary transactions (e.g. liquidations, investments or asset disposals), must be legitimate and performed in compliance with the regulations, traced, reconstructible ex post, adequately motivated, authorised and responding to company needs.)

1 3 4/ FABBRI'S GOVERNANCE

The Model therefore requires the company to behave correctly, transparently and cooperatively, in compliance with the law and internal company procedures, in all its activities, and to behave in compliance with the rules established on free competition and fair competition with other companies.

In the event of doubts as to the proper implementation of the ethical-behavioural principles during the performance of operational activities, the person concerned is obliged to consult his or her Manager (in the case of Company employees) and internal contact person (in the case of third parties) and formally submit a request for an opinion to the Supervisory Board.

GRI 205-2: COMMUNICATION AND TRAINING ON POLICIES AND PROCEDURES

TOTAL NUMBER AND PERCENTAGE OF EMPLOYEES TO WHOM ANTI-CORRUPTION POLICIES AND PROCEDURES HAVE BEEN COMMUNICATED

150

TOTAL NUMBER AND PERCENTAGE OF BUSINESS PARTNERS TO WHOM ANTI-CORRUPTION POLICIES AND PROCEDURES HAVE BEEN COMMUNICATED

EMPLOYEES BUSINESS PARTNERS

1,825 100%

2 %

No incidents of corruption were recorded during 2022.

With respect to tax governance, this is done internally through the preparation of declarations to be submitted. These declarations are verified both by the Group CFO and the Board of Statutory Auditors, as well as Auditors and finally by the Board of Directors. The approach to fiscal risks, including how risks are identified, managed and monitored, is described in the Management Document referred to in Italian Legislative Decree 231/01. With regard to compliance with the governance and risk management model, the Whistleblowing procedure is active within the 231 Model, which allows any transgressions to be reported anonymously via a specific email from the Supervisory Board outside the company organisation. Every six months, the Supervisory Board verifies compliance with Legislative Decree 231/01. Finally, any tax defence, following any sanction reports, will be carried out by external consultants (tax and tax experts) together with the Group CFO.

Francesco Casolari

Bolo Amarena 3000

Technique: Etching 94x117cm, 2022