Model pursuant to Legislative Decree no. 231/2001 and Code of Ethics

Legislative Decree 8 June 2001, n. 231 ("the Decree") introduced into our legal system the discipline regarding the administrative liability of "entities" following the commission of specific crimes. In particular, companies are liable for the commission (or attempted commission), in Italy or abroad, of certain crimes committed by subjects functionally linked to them in the interest or to the advantage of the companies themselves.

In particular, the entity may be held liable if, before the commission of the offense by one of the subjects indicated above, it had not adopted and effectively implemented organisation, management and control models suitable for avoiding crimes of the type that occurred.

In compliance with the provisions of the art. 6 of the Decree, on 18 February 2023 Essemme Srl adopted its own Code of Ethics and organisation, management and control model which describes the set of rules, processes and procedures aimed at preventing crimes considered relevant for the Company.

The task of supervising the functioning and observance of the Model, as well as ensuring its updating, has been entrusted to a Supervisory Body , with a monocratic composition.

The role is held by an external consultant who possesses the necessary requirements of good repute, professionalism, autonomy and independence.

The adoption of the Model represented an important step towards the affirmation of the ethical principles of legality and transparency and of the sense of responsibility in internal relationships and with the external world, thus offering stakeholders the best guarantees of efficient and correct management, through the introduction of procedures useful for managing any risk situations.

The Code of Ethics and Conduct is an integral part of the Model.

The Code of Ethics summarizes the principles and values ​​that Essemme Srl considers fundamental for correct and fair conduct in the conduct of business and corporate activities.

Said principles and values ​​as well as the behavioral principles indicated in Model 231 must inspire all people involved in carrying out the mission and achieving company objectives and, in particular, all collaborators and all those who act in the name and on behalf of the Company or who have relationships with it (suppliers, etc.) .

In particular, in pursuing the mission - translated into corporate objectives and, in general, in the conduct of business - the Company hopes, promotes and demands respect for the ethical principles of confidentiality, legality, accounting transparency, professionalism and trust, correctness, loyalty, honesty, fairness and equal opportunities and integrity.