Code Of Ethics - Laminazione Sottile Group - 2023

CODE OF ETHICS

1. INTRODUCTION

This Code of Ethics lays down the intrinsic principles, values and rules of conduct for the work of the Laminazione Sottile Group’s Companies (hereinafter also the “LS Group” or “Companies”).

The contents of this document are continuously updated and developed to adapt to the continuous transformation of the environment in which the LS Group operates, thereby improving the concept of Ethics spread and adopted by the Group.

This Code of Ethics is a fundamental and integral part of the 231 Organisational Model adopted by the Laminazione Sottile Group.

The Code of Ethics is based on the main current national and international laws, guidelines and regulations on corporate social responsibility, corporate governance, human rights and the environment. The document also cites the principles of corporate ethics and the rules of conduct aimed at preventing the commission, in accordance with Italian law, of the offences provided for by Italian Legislative Decree No.231/2001.

This Code expresses the ethical commitments and responsibilities of the company in the context of its activities towards its customers and in the context of its internal activities with regard to all stakeholders including shareholders, employees and contractors. The Code is therefore a set of principles that must be respected by all of its recipients in order to ensure the proper functioning, competent management and image of the Laminazione Sottile Group.

This Code of Ethics has therefore been prepared with the intention to clearly define the set of values that the Laminazione Sottile Group recognises, accepts and shares.

The Laminazione Sottile Group ensures an information and awareness programme on the provisions of this Code and its application among its relevant recipients, so that everyone who works for the Laminazione Sottile Group can carry out their work and/or job in accordance with continuous and strict compliance with the principles and values contained in this Code.

2. IDENTITY OF THE LAMINAZIONE SOTTILE GROUP

VISION

VALUES

RESPONSIBILITY

TOWARDS SOCIETY

We pursue results with respect for employees, customers and suppliers, creating value and spreading the culture of work in the region where we operate.

TOWARDS PEOPLE

We take care of our employees and their safety. We value people who express passion in their work, ethics, integrity and fairness.

TOWARDS THE ENVIRONMENT

We are committed to reducing the impact of our activities on the environment by optimising resources based on a model for sustainable growth.

TOWARDS OUR HISTORY

We want to live up to our past, steering our Group into the future, ensuring continuity and development while still respecting tradition.

“A company shaped on aluminium: innovative and reliable, dynamic and sustainable”

3. SCOPE AND SHARING OF THE CODE

This Code applies to all Group companies, in any country and at any level of the organisation.

The Code of Ethics is addressed to all members of the Board of Directors (Chairman, Managing Directors, Directors), Executives, Personnel (employees or otherwise) and Third Parties (customers, suppliers) who carry out activities with and on behalf of the Laminazione Sottile Group, whether employed by the Company or not, in all the countries in which it operates. The recipients of the rules of the Code are required to comply with the provisions contained therein and adapt their conduct and actions to the principles expressed.

The Laminazione Sottile Group shall:

• adopt, by resolution of the Board of Directors, this Code of Ethics;

• request compliance with the provisions of this Code in all internal and external relations established by it and share it as much as possible;

• provide a copy of this Code to all personnel.

In order to ensure that it is easily accessible and available to all recipients, the Code is translated into English and published on the Group’s official website www.laminazionesottile.com and on each Group company’s website.

All employees of the LS Group are required to:

(1) be familiar and compliant with the Group’s laws, regulations, policies and procedures applicable to their work; (2) seek immediate advice and guidance when in doubt about what action to take and encourage others to do the same; (3) identify and report problems or potential breaches with respect to issues that fall within the scope of the Code of Ethics; and (4) not judge or retaliate in any way against individuals who report issues or breaches or participate in an investigation.

If there is no conflict between the Code and local legislation, then both must be respected. In the event that the laws and regulations in force in a particular jurisdiction are more permissive than those contained in this Code, the latter shall prevail. If in doubt or if compliance with local law is impossible without breaching the Code or vice versa, all recipients of this document should immediately contact one of the people or groups of people listed below:

- their direct superior, the Group’s Internal Audit & Compliance unit, the Legal and General Affairs unit and the Human Resources Department;

- to report a breach or fraudulent evasion of the principles and the requirements of the Organisation, Management and Control Model pursuant to Italian Legislative Decree 231/2001 for the dedicated channels of the Supervisory Boards:

- odvls231-2001@laminazionesottile.com

odvitc231-2001@italcoat.com

odvcnt231-2001@contital.com

odvips231-2001@ipsariflex.com

4. THE ROLE OF LINE MANAGERS

Any Manager or Supervisor must set an example and therefore carry out their work in accordance with the principles and rules of conduct contained in this Code, demonstrating to other employees via their work that compliance with the Code is a fundamental aspect of their work, while ensuring that everyone is aware that the company’s results go hand in hand with compliance with the principles of the Code.

For this reason, we expect our management to meet the highest standards of ethical conduct and to encourage an understanding of the ethical implications of business decisions.

5. DISCIPLINARY SANCTIONS

Compliance with this Code of Ethics is the sole and personal responsibility of each employee. In the event of a breach, employees may not claim that they did not know about this provision or that they acted according to orders from higher-level managers as a means of justification. The Code is an integral part of the contractual obligations of any parties who deal with the Company and/or the Group’s other companies and, in particular, for employees (whether managers or not), including pursuant to Article 2104 of the Italian Civil Code (Employee diligence).

Anyone who breaches the Code or current legislation or who behaves in a manner contrary to the spirit of the Code is subject to consequences assessed and proportionate to the type and seriousness of the breach committed and the role of the subject, which may also include the possible termination of the employment relationship or any other form of contract, in addition to compensation for any damages resulting from the breach, as well as the launch of legal proceedings. Any breach of the Code shall be assessed objectively and fairly by the competent bodies, which shall apply the appropriate disciplinary sanctions.

The application of disciplinary sanctions does not depend on the outcome of any criminal or civil proceedings, since the rules of conduct laid down by the Code are effective regardless of the offence and/or crime resulting from any misconduct. No unlawful conduct or conduct that breaches the provisions of this Code or is unlawful or dishonest may be justified or considered less serious, even if carried out in the interest or to the advantage of the Group’s companies.

6. OUR ETHICAL PRINCIPLES IN CORPORATE MANAGEMENT

FAIRNESS AND COMPLIANCE WITH THE LAW

The relations that each company of the LS Group maintains with various subjects are based on the principles of transparency, fairness, collaboration, equity, loyalty and mutual respect.

Employees, regardless of their role and job, must carry out their work in the interest of the Company and in compliance with the rules of conduct set out in this Code. The information shared both inside and outside the Company must be truthful, accurate and complete. Continued compliance with these rules of conduct enables the principle of transparency to be implemented.

The Company ensures that everyone operating within it complies with the principles of fairness and loyalty in the performance of their jobs, both internal and external, including for the purposes of maintaining the Company’s image and the relationship of trust established with customers and, more generally, with third parties.

In all circumstances, all employees are required to comply with the laws which the Laminazione Sottile Group must abide by, including the laws in force in the different countries where the Laminazione Sottile Group operates or does business. Employees should be aware that, given the different countries in which the Group operates, inappropriate conduct in one country could expose the Laminazione Sottile Group or its employees to legal liability, not only in the country where this conduct occurred but also in other countries. If there is doubt over whether a proposed action or other event may expose the Laminazione Sottile Group to legal liability in other countries, employees are required to report the matter immediately to the people referred to in paragraph 2.

The Company’s activities are inspired by the rules set out in this Code, which all Recipients must follow.

DILIGENCE AND ACCURACY

Employees must carry out their duties with diligence and accuracy, in compliance with the directives issued by their line managers and, in general, with the company’s quality standards.

PROTECTION OF COMPETITION

Competition and antitrust laws aim to prohibit unreasonable restrictions on trade and to preserve competition. Examples of competition and antitrust infringements include price fixing, bid rigging, market or customer sharing arrangements, and production or sales restrictions. Sanctions for competition and antitrust infringements are serious and individuals who have committed these infringements can be severely punished, even up to imprisonment. Agreements that violate fair competition are therefore strictly prohibited. This includes business practices that may constitute a breach of antitrust rules. All employees must refrain from engaging in unfair conduct. In the context of fair competition, the LS Group shall not knowingly breach third parties’ intellectual property rights.

The LS Group refrains from any collusive or abusive conduct resulting from having market dominance and shall reject and disclose any practices aimed at distorting or reducing free competition on the market.

PROTECTION OF INDUSTRIAL AND INTELLECTUAL PROPERTY

The LS Group acts in full compliance with industrial and intellectual property rights, as well as laws, regulations and conventions, including EU and/or international contexts, to protect such rights.

In this regard, all Recipients must respect the legitimate industrial and intellectual property rights of third parties and refrain from the unauthorised use of these rights, in the knowledge that breaching these rights may have negative consequences for the LS Group.

In particular, in carrying out their work, Recipients must refrain from any conduct that may constitute a breach of industrial property rights, alteration or counterfeiting of trademarks and/or distinctive signs of industrial products, or of patents, designs or industrial models, both domestic and foreign, and refrain from importing, marketing or in any case using or otherwise putting into circulation industrial products with counterfeit or altered or misleading trademarks and/or distinctive signs or made by violating industrial property rights.

COMBATING CORRUPTION AND CONFLICTS OF INTEREST

The Laminazione Sottile Group does not tolerate any form of corruption, is committed to complying with the anti-corruption laws in force in all the countries in which it operates and requires all its stakeholders to act with honesty and integrity at all times. All business decisions and choices made on behalf of the Laminazione Sottile Group must correspond to its best interest and be in line with corporate values.

Employees must therefore avoid situations and/or activities that could lead to conflicts of interest with the Company, or that could interfere with their ability to make impartial decisions, in order to safeguard the Company’s best interests. These activities could financially harm the Company, but more importantly, they could damage its reputation.

Any situation that could lead to an actual or potential conflict of interest must be reported and referred to the people indicated under paragraph 2.

ANTI-MONEY LAUNDERING

The LS Group is committed to preventing the use of its economic-financial system for the purposes of money laundering and the financing of terrorism (or any other criminal activity) by its Customers, Suppliers, Employees and partners which it deals with in running its business. The LS Group checks with the utmost diligence any information available on its business partners, consultants and suppliers, in order to ascertain their respectability and the legitimacy of their business before establishing any form of business relationship.

Employees are required to strictly comply with the law, company procedures and policies in any financial transaction, including intra-group transactions involving them, ensuring full traceability of incoming and outgoing financial flows and full compliance with anti-money laundering laws.

CORPORATE SOCIAL RESPONSIBILITY

Corporate Social Responsibility is the way in which the LS Group aims to emphasise the social impact of its facilities and activities, upholding the principles and values that steer the Group both in its internal processes and methods and in its interactions with other entities.

The LS Group expresses its strong commitment to the principles of Corporate Social Responsibility as an integrated part of its policies and relationships with customers, suppliers and all interested groups with which it interacts. In this regard, the Laminazione Sottile Group, in line with the company's objective of generating wealth and well-being for the community, adopts company ethics that make it possible to harmonise the creation of value with sustainable development whose main objectives are environmental protection, social cohesion and coherent communication.

INTERNAL CONTROL SYSTEM

Within their respective jobs, all employees are required to ensure that internal controls are respected and function properly. Internal controls are all the controls necessary or useful for the evaluation, management and control of the activities of the Laminazione Sottile Group. The objective is to ensure compliance with this Code and the policies and procedures adopted by the Laminazione Sottile Group.

These controls are designed to protect company assets, manage operations effectively, provide accurate and complete accounting information and prevent illegal conduct. The Management is mainly responsible for the creation of an effective internal control system, but employees at all levels of the organisation are responsible for adhering to the established controls and identifying and reporting any perceived weaknesses or malfunctions for the proper functioning of internal controls, making use of the Group’s Internal Audit department, which operates independently and objectively in line with international professional standards.

ACCOUNTING REGULARITY

Financial resources are managed by following the principles of transparency, verifiability, consistency and appropriateness. Accounting transparency is based on the existence, accuracy and completeness of the basic information for the relevant accounting records. Each director, employee, contractor and service provider is required to ensure that management operations are represented correctly and promptly in accounts. For each operation, adequate supporting documentation of the activity carried out must be kept in the records, so as to allow (i) easy recording in accounts, (ii) identification of the different levels of responsibility. (iii) the accurate reconstruction of the transaction, also to reduce the probability of misinterpretation. The LS Group is committed to training all personnel responsible for the creation and recording of accounting operations.

GIFTS, DONATIONS AND OTHER UTILITIES

Giving or receiving business courtesies from third parties is allowed, as long as they are of modest value and do not compromise the recipient’s integrity and reputation or influence their independent judgement. All acts aimed at any form of corruption with third parties, whether private or public, are expressly prohibited, as they are completely contrary to the Group’s culture.

Employees are prohibited from accepting or soliciting promises or payments of money or goods or benefits, as well as applying pressure or offering services of any kind that may be aimed at promoting the hiring of an employee or their transfer or promotion.

It is important that they are directly related to a legitimate business purpose and that their offer or acceptance is strictly limited in terms of value and frequency and does not give the impression of being an offence. Do not offer gifts or hospitality if you know that the recipient’s code of conduct prohibits accepting them.

The Laminazione Sottile Group ensures the confidentiality and protection of the information acquired as a result of the work carried out, in order to prevent it from being used for its own interests so as to gain undue profit, or for purposes that break the law or damage the Company.

Purely by way of example but not limited to, information on the following is considered confidential: products, technical, technological and commercial knowledge of the Company, work projects, including commercial, management, industrial and strategic plans, data relating to know-how and technological processes, financial transactions, operating strategies, investment and divestment strategies, operating results, personal data of employees and lists of customers and business partners, information relating to present and future activities, including information not yet shared, even if covered by forthcoming announcements, minutes of meetings, procedures, regulations, contracts, organisational charts, and information systems.

All notes, memos, minutes and writings (including copies) generated within the Companies, all information and other material obtained by each of the Recipients in relation to their position within the LS Group or because of the fact that they are in business with it, are and shall remain the exclusive property of the LS Group with which the Recipients have a working or business relationship.

All Recipients are required to provide the Company with the aforementioned documents, information and materials at the latter’s request and, in any case, upon termination of the employment or business relationship with the Company.

The LS Group’s confidential information must never be shared with anyone who does not need to know this information to carry out work or services for the Laminazione Sottile Group. As a general rule, confidential information may only be shared with authorised people. Even within the Group’s companies, confidential information must only be shared when necessary. Personnel must follow all security procedures and avoid situations that may lead to the loss, misuse or theft of LS Group information. Other information of third parties with whom the LS Group does business or interacts must also be respected.

The obligation of confidentiality regarding information concerning the technical, technological and commercial knowledge of the Company, as well as other non-public information relating to the Company, shall remain in force even after the termination of the employment relationship.

When processing this data and information, the Recipients shall therefore protect the information acquired and/or generated and avoid any improper and/or unauthorised use thereof. Failure to comply with the obligation of confidentiality shall be considered a serious breach of this Code.

CONFIDENTIALITY AND PROTECTION OF PRIVACY

As part of running its business, the Laminazione Sottile Group collects a significant amount of personal data and confidential information, which it shall process in accordance with all applicable laws in its jurisdiction and the best practices applied in relation to confidentiality and privacy.

The Company, which has already complied with the requirements of the previous reference laws (Italian Legislative Decree 196/2003) on the protection of personal data, currently operates in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 (General Data Protection Regulation, also known as the “GDPR”). The Company respects the rights granted to data subjects by the Privacy Regulation, whether they are employees, customers or suppliers of the Company, providing them with a complete and updated policy on the processing of data - both common and data that falls into “special categories” - acquired by the Company or which shall be acquired and/or processed in the course of its business, having identified the appropriate legal grounds for the various kinds of processing, and applying the principles put in place by the Privacy Regulation (including the principles of lawfulness, fairness and transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity and confidentiality and accountability).

The Laminazione Sottile Group shall ensure that the personal information acquired is suitably protected, according to the terms provided for by the privacy regulations, avoiding improper or unauthorised use, to protect the dignity, image and confidentiality of each party, whether inside or outside the Group. The processing of personal information is carried out lawfully and properly. Personal information is collected and stored only when it is necessary for certain explicit and legitimate purposes. Data shall only be retained for a period of time no longer than is necessary for the aforementioned purposes.

For greater protection and transparency regarding data subjects, in its role as the data controller, the Company has established an in-house appointment system in order to entrust specific personal data processing tasks to qualified internal staff.

In complying with the rules under Article 29 of the GDPR, the Laminazione Sottile Group has arranged to officially provide all authorised data processors with specific instructions for the type of work which each of them shall have to carry out on this data.

WORKPLACE HEALTH AND SAFETY

The Company shall support, spread and strengthen a culture of workplace health and safety, developing awareness of risks and promoting responsible behaviour by all employees.

The Company also promotes a culture of workplace safety through informational and training meetings for personnel. The Company’s activities must be carried out in full compliance with the OHSAS 18001/ISO 45001 standards and the Health and Safety principles contained in the Quality, Health, Safety and Environmental Policy in order to integrate the principles of sustainable development into all its activities worldwide.

"Zero accidents" is the main priority of the Laminazione Sottile Group in terms of safety in all its plants. It pursues this objective by committing to guarantee the safety of all its offices and factories in accordance with the highest applicable standards and by promoting awareness of this primary objective among all its Employees. The LS Group has chosen as its top priority to adhere to the OHSAS 18001/ISO 45001 safety certification system, thus committing to reducing exposure to risk in the workplace and improving the Safety Management System and its performance, through consultation, participation and training of all personnel.

Regardless of where they work (factory/office/region), each employee must be actively involved in protecting their own health and that of others, whether they are employees, visitors, suppliers, customers or members of the communities in which they operate.

RESPECT FOR THE ENVIRONMENT, CULTURAL AND LANDSCAPE HERITAGE

The Laminazione Sottile Group is committed to protecting natural resources and the environment. The Group considers the environment as one of its top values and runs company activities in full accordance with existing environmental legislation. To that end, all recipients of the Code of Ethics must operate in line with the following principles:

• taking all the steps required to ensure respect for and compliance with the regulatory provisions in force;

• promoting a culture of environmental respect and ensuring constant staff training for legislative and regulatory changes on environmental issues;

• integrating attention to environmental issues into the activities performed and increasing staff awareness about environmental problems, in order to achieve high professional standards;

• monitoring technological progress and assessing its implementation when it can guarantee better environmental protection.

The LS Group has chosen to adhere to the ISO 14001:2015 environmental certification system, making a commitment to developing a sustainable business, preventing pollution and minimising the environmental impact of its activities, while using natural resources and energy in the most efficient manner.

The LS Group communicates its QHSE policy throughout the organisation, training its employees in the correct use of Quality, Health, Safety and Environmental management systems.

The LS Group’s Companies shall refrain from carrying out any activities that could constitute a breach of the regulations put in place to protect any heritage with landscape or cultural relevance and/or interest.

If the LS Group has to promote or take part in capital investment or funding activities regarding works of art or art collections or restorations of prestigious assets, it shall focus on people with appropriate profiles who can prevent money laundering or the receipt of stolen goods, or breaches of binding regulations.

If company activities have an impact on an environmental situation subject to landscape, cultural or valuable art restrictions, they must be carried out in full compliance with any relevant technical regulations (Code of the Cultural and Landscape Heritage).

EMPLOYEES AND THE WORKING ENVIRONMENT

The LS Group considers respect for employees and their personal growth as an inviolable principle, promotes a healthy and safe working environment, and prevents discrimination and harassment in employment relationships.

The Code of Ethics is an integral and substantial part of every employee's employment contract. The Laminazione Sottile Group therefore requires all employees to strictly comply with the provisions of the Code of Ethics. Any breach of these provisions is therefore treated seriously and appropriate disciplinary measures shall subsequently be taken.

The Company is committed to offering equal employment and professional advancement opportunities to all Employees, creating initiatives to increase their skills and abilities.

Employees must be treated, in all aspects of the employment relationship, such as recruitment, training, remuneration, promotions, transfers and termination of the relationship, in a manner consistent with their ability to meet the requirements of the job, avoiding all forms of discrimination and, in particular, discrimination on the basis of race, sex, age, nationality, religion, personal beliefs, political opinions or state of health.

The Laminazione Sottile Group is committed to protecting the physical and mental well-being of its people, protecting the physical and moral integrity of its employees and contractors, and ensuring working conditions that respect the dignity of the individual, all in full compliance with individual and collective agreements, the Workers’ Statute (Statuto dei Lavoratori) as well as current legislation on the health and safety of workers and laws governing human rights and work. The Company seeks to eliminate all forms of discrimination, illegal or forced labour, slavery or servitude, in particular child labour.

Discrimination, illegal or forced labour, slavery and servitude, in particular child labour at LS Group suppliers, contractors and associated persons, shall not be tolerated.

The LS Group’s Companies shall ensure that no acts of violence, psychological coercion or surveillance take place, as well as any attitudes or conduct that harm people’s dignity.

In managing employment relationships, it is prohibited to pay wages in different ways from those set out in national or regional collective agreements stipulated by the most representative trade union organisations at national level and, in any case, it is prohibited to pay disproportionate wages for the quantity and quality of work provided.

The LS Group’s Companies are committed to complying with legislation on working hours, rest periods, weekly rest, compulsory leave and holidays, unless for justified exceptions which are traceable and based on agreements reached with trade union organisations to be notified immediately to the Supervisory Board.

The LS Group’s Companies also ensure that no conduct takes place aimed at persuading or forcing employees, either directly or indirectly, to breach this Code of Ethics or internal regulations.

Anyone has the right to apply for a position within the LS Group or to be considered for a new position in accordance with the requirements and criteria of merit, without discrimination. Hiring takes place under a regular employment contract and in full compliance with current and applicable legislation on working hours, rest periods, weekly rest, compulsory leave, holidays, and the provisions contained in the Collective Labour Agreement. When the collaboration begins, the employee must receive exhaustive information on the Contract, with particular reference to the characteristics of the duties to be performed and of the company function to which they are assigned, as well as on the remuneration aspects, principles and rules contained in the Code of Ethics.

The evaluation of individual performance must take into account not only “what” has been achieved but also “how” the results have been achieved, rewarding respect for and compliance with the conduct and principles adopted by the LS Group.

CUSTOMERS, SUPPLIERS AND PARTNERS

In its relations with its customers - private entities - LS acts in a way that is inspired by the principles of transparency, reliability, responsibility and quality. These relations must be based on the principles of mutual transparency and respect for market rules through reliable and proper conduct, while guaranteeing complete and accurate information on any products and services offered. Towards the Customer every Employee must:

• act according to the principles of mutual competition, good faith and timely fulfilment of contractual obligations;

• strictly follow the provisions of this Code of Ethics and the internal procedures for the management of relations with customers, as well as all contractual provisions defined according to current legislation;

• ensure the quality and reliability of the services offered;

• avoid any venture that could bring unwarranted favouritism, benefiting one customer over others;

• avoid receiving money or any other utility or benefit, even if modest in value, to carry out, certify or adopt an act contrary to official duties;

• avoid receiving donations, gifts or other benefits, even if modest in value, if the donation is intended to obtain unlawful benefits.

In its relations with Suppliers, LS is inspired by the principles of absolute honesty, loyalty, good faith, fairness, impartiality, transparency and free competition.

Suppliers shall observe and respect the values and principles expressed in this Code. The Laminazione Sottile Group is committed to ensuring fair opportunities for any potential Supplier, in accordance with the principles of transparency, in order to develop relationships of collaboration and cooperation through a process of constant communication for a mutual partnership. The selection of Suppliers must be based on the evaluation of the quality of their services and products, as well as their competitiveness, and also on the compliance of their professional and technical performance with specifications, and on aspects of social responsibility.

All employees must:

• deal with the Group’s suppliers with transparency and fairness, ensuring equal opportunities;

• observe and respect, in supply relationships, the provisions of the law and regulations in force as well as those laid down by the Company on the subject;

• strictly comply with the set of rules provided for by current regulations and organisational procedures regarding the selection of suppliers;

• comply with the contractual conditions, managing the relationship with the supplier in the correct manner;

• avoid any venture that could bring unwarranted favouritism, benefiting one supplier over others;

• avoid receiving money or any other utility or benefit, even if modest in value, to carry out, certify or adopt an act contrary to official duties;

• avoid receiving donations, gifts or other benefits, even if modest in value, if the donation is intended to obtain unlawful benefits.

The sharing of the Code of Ethics is a necessary prerequisite for the establishment and maintenance of supply relationships. Every Group Supplier must respect the values and principles expressed in this Code, bearing in mind that failure to comply with the provisions contained within it may lead to the end of the supply relationship.

Relations with these subjects must be lawful and transparent and must be managed exclusively by company staff expressly delegated and authorised to do so.

It is prohibited to make any form of payment or to offer or receive any utility of value as part of relations with public administration in order to obtain or retain an appointment or any other advantage for the LS Group.

In relations with Public Administration officials/employees, it is prohibited to offer gifts, acts of hospitality or entertainment expenses (regardless of their value). It is prohibited to make any form of payment or to offer or receive any utility of value as part of relations with public administration in order to obtain or retain an appointment or any other advantage for the LS Group.

Any form of payment to political parties or organisations, their representatives or political campaigns is prohibited.

The LS Group deals with the supervisory authorities with the utmost transparency, clarity and fairness, so it does not lead to any partial, distorted, ambiguous or misleading interpretations. In view of the confidentiality and sensitivity of relations with such entities, only specifically appointed people are allowed to deal with public institutions and supervisory authorities.

The LS Group shall:

• establish, without any kind of discrimination, stable channels of communication with all institutional stakeholders at international, Community and regional level;

• represent the interests and positions of the Company in a transparent, thorough and consistent manner, avoiding any collusive conduct.

Recipients who, in any capacity, either directly or indirectly, access public administration’s online or computer systems must not alter how they operate in any way, interfering without the right to do so in any way whatsoever with data, information and programs.

In its relations with the financial authorities, the Company promotes the principle of transparency and clarity for the data on which the declarations provided are based, guaranteeing in any case the traceability of any decisions made and the sharing of these decisions with subjects who have specific and proven professional expertise. The Company also guarantees the full compliance of any declarations to be made under existing regulations, using computer systems and professional consultations in order to check the existence at any time of regulations that have any relevance for making declarations. All of this is done in order to pay any taxes and duties owed, without any exception whatsoever, in full compliance with the law.

RELATIONS WITH THE COMMUNITY

The LS Group considers the population and local communities of the countries where it operates as among its main Stakeholders and is committed to fostering relations with them in the forms provided for by the applicable laws in the various legal systems.

Its development of social initiatives, cultural projects and events and its support for various associations prove the commitment of the Laminazione Sottile Group towards the Community and the region where the Group operates.

7. WHISTLE-BLOWING

The LS Group’s Companies comply with the provisions of Italian Legislative Decree No. 24/2023, which provides for the implementation of Directive (EU) 2019/1937 of the European Parliament and Council of 23 October 2019 on the protection of persons who report breaches of Union law and regarding the provisions on the protection of persons who report breaches of national legislation.

In line with the General Section of the Model, the Company has adopted a variety of dedicated channels to report offences by employees, members of the company’s bodies and external contractors.

An external subject indicated in the General Section of the Model is entrusted with managing the channel for each report, to be made in writing, on a computer or orally.

The LS Group’s Companies apply the following principles when handling reports:

1. Reports may not be used for longer than is necessary to follow up on them appropriately.

2. The whistle-blower’s identity and any other information that might be discovered about them, either directly or indirectly, may not be revealed without the whistle-blower’s express consent to anyone else other than the people in charge of receiving or following up on reports, who are expressly authorised to process this data pursuant to Articles 29 and 32, paragraph 4, of Regulation (EU) 2016/679 and Article 2-quaterdecies of the personal data protection act under Italian Legislative Decree No 196 of 30 June 2003.

3. During disciplinary proceedings, the whistle-blower’s identity may not be revealed, when a formal reprimand for the disciplinary complaint is based on additional separate investigations regarding the report, even if resulting from it. If the formal reprimand is based, either wholly or in part, on the report and knowledge of the whistle-blower’s identity is essential for defending the accused, the report may be used for the purposes of disciplinary proceedings solely with the whistle-blower’s express consent to reveal their identity.

4. Internal and external reports and the relative documentation are kept for the time required to handle the report and, in any case, not for longer than five years starting from the date when the final outcome of the reporting procedure is notified, in accordance with the obligations of confidentiality under Article 12 of this Decree and the principle under Article 5, paragraph 1, letter e) of Regulation (EU) 2016/679 and Article 3, paragraph 1, letter e) of Italian Legislative Decree No 51 of 2018.

5. If a recorded phone line or another recorded voice-messaging system is used for submitting reports, then the report shall be documented, subject to the whistle-blower’s consent, by authorised staff through a recording on an adequate device for storing and listening or through a full transcription. In case of transcription, the whistle-blower may verify, correct or confirm the contents of the transcription by signing the document.

6. If a non-recorded phone line or another non-recorded voice-messaging system is used for submitting reports, then the report shall be documented in writing through a detailed account of the conversation by an authorised member of staff. The whistle-blower may verify, correct or confirm the contents of the transcription by signing the document.

7. When the report is made orally, at the whistle-blower’s request, at a meeting with an authorised member of staff, the report shall be documented, subject to the whistle-blower’s consent, by authorised staff through a recording on an adequate device for storing and listening or through written minutes. In case of minutes, the whistle-blower may verify, correct or confirm the minutes of the meeting by signing the document.

8. The whistle-blower shall not suffer any form of reprisal.

This is obviously without prejudice to the whistle-blower’s right, at the same time or as an alternative to the report covered by this procedure, to file a complaint with the Authorities regarding what they witnessed or know.