The Organization, Management and Control Model ex Italian Legislative Decree no. 231/2001 consists of a series of rules, protocols, instruments and procedures, designed to provide the Company (and the Group Companies) with an effective and adequate organizational, management and controlling system appropriate to identify and prevent risks of crimes commission, relevant under Italian Legislative Decree no. 231/2001, by people within the Company or functionally related to the Company, in the interest or for the benefit of the Company itself.

Adoption and effective implementation of the 231 Model is the essential condition to exempt the Company from administrative liability, pursuant to Legislative Decree no. 231/2001. The Model, adopted by the Company since 2003, has been progressively updated in the face of organizational and regulatory changes that have affected the Company over the years, with a view to continuous improvement.