Code of Ethics
and Legislative Decree
no. 231/2001

Roveda S.r.l. (hereinafter the “Company“), in order to comply with the provisions of Legislative Decree No. 231 of June 8, 2001 (“Decree 231/01“) – as well as the obligations imposed by the Civil Code1 – and to ensure conditions of increasing fairness and transparency in the conduct of its business, has deemed it necessary and appropriate to adopt an Organization, Management, and Control Model (hereinafter, the “Model“).

The Company believes that adopting a Model in accordance with the provisions of Decree 231/01 constitutes a valuable tool for raising awareness not only among employees but also among all collaborators and individuals who have contractual relationships with it (such as customers, suppliers, and Public Administrations). This is to encourage them to adopt correct and transparent behaviors in line with the ethical and social values that Roveda upholds in pursuit of its social objectives.

In particular, the adoption, effective implementation, and dissemination of the Model aim, on one hand, to create a full awareness in potential wrongdoers that illicit conduct is not only severely condemned by the Company but is also contrary to the values and interests pursued by the Company. On the other hand, it aims to enable the timely prevention of offenses through constant monitoring of related behaviors.

Furthermore, the Company believes that, in addition to these primary objectives, there are other goals that emphasize the importance of adopting a Model and introducing it appropriately into its corporate structures, such as creating a proper culture of control, risk management, and protection of the Company’s image and reputation.

In light of these considerations, the Company initially conducted an analysis of its entire organizational structure and internal control system to verify the alignment of the existing behavioral principles and procedures with the purposes specified in Decree 231/01. Subsequently, to further enhance a corporate culture oriented towards the highest standards of ethics and legality, it also adopted a Code of Ethics that clearly identifies and defines the fundamental ethical values and rules of conduct that all Company personnel are required to adhere to in the performance of their activities.

The Model, the Code of Ethics, the principles of behavior, and the control protocols contained in these documents are addressed to all those who, in any capacity, work on behalf and/or in the interest of the Company, i.e., all the individuals referred to as “Recipients” in the general part of the Model itself, including:

a) administrators;

b) members of corporate bodies;

c) any other individuals in top positions (defined as anyone who holds functions of representation, management, administration, direction, or control of the Company);

d) employees and external collaborators in any capacity (permanent, fixed-term, part-time, temporary, interns at any level, and under any type of contractual relationship, even if based abroad) subject to the direction or supervision of the so-called top individuals of the Company.