231 Model, Code of Ethics , Whistleblowing Policy

The Legislative Decree 231/2001 (the “Decree”) introduced into Italian law the regime of administrative liability of Entities for certain offenses committed – in their interest or for their benefit – by board members or persons under their direction or supervision.

In order to ensure the prevention of such offenses specified in the Decree, Smemoranda Group has adopted its own model of organization, management and control (the «Model»), approved by the Board of Directors on October 17th, 2016.

The Model is part of a wider policy of Smemoranda Group and it aims to promote fairness and transparency of the group in conducting its own activities and in relation with third parties. To the same end, a Code of Ethics was adopted by Smemoranda Group and all its companies..

Smeoranda Group Board of Directors has established a Compliance Committee with independent powers of initiative and control and in charge of overseeing the functioning and observance of the Model and to promote its updates.