Compliance with the law, transparency and fairness in management, trust and cooperation with stakeholders are the ethical principles that inspire Lormar S.r.l. and from which its models of conduct derive, in order to compete effectively and fairly in the market, improve customer satisfaction, increase value for shareholders, and develop the skills and professional growth of its human resources.

To this end, Lormar S.r.l. requires its shareholders, Directors and employees in general (even in the event of changes to the shareholding structure), as well as anyone who, in any capacity, performs representative functions, even de facto, to comply with the legislation and all applicable rules and the principles and procedures established for this purpose, as well as ethically correct conduct that does not compromise their moral and professional reliability.

Lormar S.r.l. also complies with and respects all further obligations arising from contractual and industry regulatory sources.

Honesty represents the fundamental principle for all of Lormar S.r.l.'s activities, initiatives, reports and communications, and constitutes an essential element of its management. Relationships with stakeholders are based on criteria and conduct of fairness, cooperation, loyalty and mutual respect.

Lormar S.r.l. recognises the fundamental value of correct information to shareholders, bodies and competent functions, regarding significant facts concerning corporate, business and accounting management.

Lormar S.r.l. pursues its corporate purpose in compliance with the law, its Articles of Association and internal regulations, ensuring the correct functioning of the corporate bodies and the protection of the property and participation rights of its shareholders, while safeguarding the integrity of the share capital and assets.

Lormar S.r.l. ensures the confidentiality of the information in its possession and refrains from seeking confidential data through illegal means.

Lormar S.r.l. also adheres to the personal data protection regulations set out in the GDPR, EU Regulation 679/2016. In particular, the Company undertakes to formalise — in a separate document, forming an annex to the Model — the procedures for collecting, storing and managing personal data in compliance with the new principles of privacy by design and privacy by default, with a view to the general accountability of the data controller. What has just been specified also applies, indeed primarily, to the health data of employees, suppliers, customers and stakeholders in general, which Lormar S.r.l. has come into possession of as a result of the procedures put in place to prevent the spread of Covid-19.

All information available to Lormar S.r.l. is in any case handled in compliance with the confidentiality and privacy of the individuals concerned.

Within the various relationships with the Company or with its interlocutors, recipients of this Code must refrain from using confidential and non-public information, of which they have become aware by reason of their office and/or profession, for personal purposes and, in any case, not connected with the work or professional activity entrusted to them or carried out within the Company.

The Company promotes respect for the physical and cultural integrity of the individual and respect for the dimension of relationships with others. It guarantees working conditions that respect individual dignity and safe working environments, and applies to its employees the legislation and employment contracts in force, rejecting corporate policies of modern slavery.

The Company has adopted the principles of European Commission Recommendation 93/131/EEC of 27 November 1991 in drafting this Code of Ethics.

In order to avoid even potential situations of conflict of interest, when assigning duties or entering into employment relationships, the Company requires its Directors, employees and collaborators of any kind to assess and rule out the presence of conditions of conflict of interest between the individual and the Company.

Lormar S.r.l. further requires that anyone who becomes aware of a situation of conflict of interest promptly report it to the Supervisory Body.

The environment is a primary asset that Lormar protects, in compliance with the principles of sustainable development, as well as strict compliance with environmental regulations (including the Environmental Consolidated Act, Legislative Decree 152/2006).

To this end, the Company plans its activities seeking a continuous balance between economic initiatives and social and environmental needs, and promotes a culture of safety and risk prevention among all stakeholders.

Lormar S.r.l. considers it of primary importance to guarantee a high quality standard to the end recipients of its products.

To this end, the Company outlines and pays particular attention to all phases of sourcing the materials used in production, through a careful selection of suppliers, a list of which is kept and periodically updated within the Company.

Lormar S.r.l. creates the conditions for shareholders' participation in decisions within their remit to be widespread and informed, promotes equality and completeness of information, and protects their interests. The corporate governance system adopted by the Company complies with the requirements of the law and is primarily aimed at:

• achieving maximum transparency towards the Company's stakeholders;
• controlling risks;
• meeting the legitimate expectations of shareholders;
• avoiding any type of transaction to the detriment of creditors.

Lormar S.r.l. ensures the keeping of accounting records, the preparation and drafting of the annual financial statements, reports, statements, corporate communications in general and anything else required for its operation, in compliance with legal provisions, principles and applicable technical standards.

To this end, the Company oversees the conduct of the Administrative Body, officers, or persons under their supervision who are, in any capacity, involved in the preparation of accounts, financial statements or other similar documents.

Lormar S.r.l. promotes correct and timely information to all bodies and functions concerned regarding the preparation of the financial statements, the annual financial statements, reports, statements, corporate communications in general and anything else required for its operation, in compliance with legal provisions, principles and applicable technical standards. It also fosters proper cooperation between the aforementioned bodies and corporate functions and facilitates the checks carried out by the competent bodies and functions.

Every transaction and operation is correctly authorised, carried out and recorded, and a record thereof is kept so as to allow it to be easily traced, precisely recorded in the accounts, and to allow the different levels of responsibility to be identified, as well as allowing the transaction to be accurately reconstructed, also to reduce the likelihood of interpretative errors.

Lormar S.r.l. recognises the central role of human resources, their psychophysical health, and the importance of establishing and maintaining relationships based on loyalty and mutual trust. In this sense, human resources are understood to include both employees and collaborators who work for the Company under contractual arrangements other than employment.

All employees/collaborators undertake to act loyally in order to fulfil the obligations assumed under their employment contract and under this Code of Ethics, providing the services required of them and honouring their commitments.

Personnel selection and establishment of the employment relationship.

The assessment of personnel to be hired is carried out on the basis of how well candidates' profiles match those expected and the Company's needs, in compliance with the principles of impartiality and equal opportunities for all parties concerned.

All personnel are hired under a regular employment contract; no form of undeclared or irregular employment is permitted.

When a collaboration begins, including in the form of an internship, the employee/collaborator receives comprehensive information regarding the characteristics of the tasks and functions, the applicable pay and regulatory terms, and the rules and conduct for managing risks related to personal health. The employee/collaborator is also given adequate training in relation to the type of tasks they will be required to perform.

Human resources management policies.

Any form of discrimination against individuals is prohibited.

All decisions made in the context of human resources management and development are based on considerations of merit and/or the match between expected profiles and the profiles held by collaborators. The same applies to access to different roles or positions.

In managing hierarchical relationships, authority is exercised with fairness and correctness, avoiding any abuse thereof. It constitutes an abuse of a position of authority to request, as if owed by a subordinate, personal services, favours or any conduct constituting a violation of this Code.

Human resources are fully valued through the activation of the tools available to foster their development and growth.

The relevant functions must therefore:

• select, hire, train, remunerate and manage employees or collaborators without any discrimination;
• create a working environment in which personal characteristics cannot give rise to discrimination;
• adopt merit-based, competence-based and, in any case, strictly professional criteria for any decision relating to an employee or collaborator.

Use of external labour.

Lormar has entered into, in the past, and may enter into, in the future, contracting and/or labour supply agreements for production purposes or, more generally, for the management of the business.

During 2024, all existing labour contracting agreements were reviewed with the assistance of external consultants, in order to ensure that the agreements in question complied with the applicable contractual archetype, thereby avoiding any disputes, whether from an employment-law perspective or a criminal-law perspective (both with regard to unlawful labour intermediation and tax offences).

It follows that, as of the drafting/revision of this Model, all of the Company's agreements comply with the applicable regulatory framework.

Should the need arise to enter into further labour contracting agreements, the Company undertakes to formalise them in accordance with statutory criteria and with the assistance of professionals specifically engaged for that purpose.

Lormar S.r.l. promotes and spreads a culture of workplace safety and environmental protection, developing awareness of risk management, promoting responsible conduct and preserving, especially through preventive action, the health and safety of all employees and collaborators, the healthiness of workplaces, and respect for the environment in all its aspects.

All operators at Lormar S.r.l. (shareholders, managers, employees and collaborators) are required to scrupulously observe the rules and obligations arising from the applicable regulations on health, safety, workplace healthiness and environmental protection, as well as to adopt and fully comply with all measures and procedures on health, safety and the environment set out in the company's safety assessment system, environmental protection framework and internal regulations.

Lormar S.r.l. has also adopted a specific Protocol, to be understood as an annex to the Model, concerning corporate social distancing policies, in compliance with the "Shared protocol for regulating measures to combat and contain the spread of the Covid-19 virus in the workplace", signed by the Government with the social partners in March 2020.

The privacy of employees and collaborators is protected in compliance with the applicable regulations, now aligned with the aforementioned European Regulation, including through operating standards that specify the information received and how it is processed and stored. Any investigation into individuals' ideas, preferences, personal tastes and private life is excluded.

Employees/collaborators are required to know and implement the Company's policies on information security, in order to guarantee its integrity, confidentiality and availability.

Every employee/collaborator has a duty to ensure the confidentiality required by the circumstances for any information learned by reason of their work function.

Every employee/collaborator of Lormar S.r.l. is required to avoid all situations and activities in which a conflict with the Company's interests may arise, or which may interfere with their ability to make decisions impartially in the Company's best interest and in full compliance with the rules of the Code of Ethics. They must also refrain from deriving personal advantage from acts of disposal of corporate assets or from business opportunities of which they have become aware in the course of performing their duties.

Lormar S.r.l. recognises and respects the right of its employees and collaborators to participate in investments, business or other activities outside of those carried out in the Company's interest, provided that such activities are permitted by law and contractual regulations and are compatible with the obligations assumed as employees and collaborators.

Any situation that may constitute or give rise to a conflict of interest must be promptly reported by each employee/collaborator to their superior or corporate contact, or to the SB responsible for overseeing the Code of Ethics. In particular, all employees and collaborators of Lormar S.r.l. are required to avoid conflicts of interest between personal and family economic activities and the duties they perform within their organisational unit. By way of example, but not exhaustively, the following situations give rise to conflicts of interest:

• holding senior positions (Administrative Body, director, head of function) while having economic and financial interests in suppliers, customers, competitors or business partners of Lormar S.r.l.;
• using one's position within the Company or information acquired in the course of one's work in such a way as to create a conflict between one's personal interests and those of the Company;
• carrying out any kind of work activity for customers, suppliers or competitors;
• accepting or offering money, favours or benefits from persons or companies that are, or intend to enter into, business relationships with Lormar S.r.l.

Should even the mere appearance of a conflict of interest arise, the collaborator is required to inform their superiors and/or the Supervisory Body.

Every employee/collaborator is required to act with due care and diligence to protect the Company's assets, through responsible conduct in line with the operating procedures established to regulate their use, documenting such use where appropriate.

Every employee/collaborator is responsible for protecting the resources entrusted to them, including PPE (including, of course, health-related PPE), and has a duty to promptly inform the relevant departments of any threats or events harmful to the Company or its assets.

In particular:

• every employee/collaborator must avoid improper use that may cause undue costs, damage or reductions in efficiency, or that is otherwise contrary to the Company's interests;
• every employee/collaborator must scrupulously follow internal policies and procedures, in order not to compromise the functionality, protection and security of the Company's IT systems, equipment and facilities;
• every employee/collaborator must always act in compliance with the safety regulations set out by law and internal procedures, in order to prevent possible damage to property, persons or the environment;
• every employee/collaborator must use the Company's assets, of any type or value, in compliance with the law and internal rules;
• all Company-owned assets are to be used exclusively for purposes connected and instrumental to the performance of work activities and, in any case, except where provided for by specific rules, the use or transfer of such assets by or to third parties, even temporarily, is prohibited;
• every employee/collaborator must cooperate, as far as possible, to reduce the risk of theft, damage and other threats to assigned or on-site assets and resources, promptly informing the relevant functions in the event of anomalous situations (employee reporting form).

Every employee/collaborator is required to be familiar with the rules contained in the Code of Ethics and the applicable rules governing the activity carried out within their function, arising from law, from the procedures provided for by the safety assessment and Environmental Protection system, or from internal or industry regulations.

Every employee/collaborator must also explicitly accept the commitments arising from this Code of Ethics upon establishment of the employment relationship or upon first dissemination of the Code.

In particular, employees/collaborators are obliged to:

• refrain from conduct contrary to the rules contained in the Code;
• consult their superiors, corporate contacts or the SB in the event of a request for clarification on how it is to be applied;
• promptly report to their superiors, corporate contacts or the SB any information, whether directly observed or reported by others, concerning possible violations of the Code and any request made to them to violate it;
• cooperate with the bodies responsible for investigating possible violations;
• adequately inform any third party with whom they come into contact in the course of their work activity about the existence of the Code and the commitments and obligations it imposes on external parties;
• demand compliance with the obligations that directly concern their activity;
• take appropriate internal and, where within their remit, external initiatives in the event of a third party's failure to comply with the obligation to conform to the rules of the Code.

The Company's approach towards customers and suppliers is based on availability, respect and courtesy, in a spirit of collaborative and highly professional relationships.

Lormar S.r.l. pursues its mission by offering quality services, at competitive terms and in compliance with all rules protecting fair competition.

Employees and collaborators of the Company are required to:

• provide, efficiently, courteously and promptly, within the limits of contractual provisions, high-quality services that meet customers' reasonable expectations and needs;
• provide, where necessary and in the manner and form set out in company policies, accurate and comprehensive information about the Company's products and services, so that customers can make informed decisions;
• adhere to the truth in advertising or other communications.

A correct and transparent relationship with customers and suppliers is a significant factor in the Company's success.

The selection of suppliers and the determination of purchase conditions are based on objective parameters, foremost among which are quality, value for money, price, capability and efficiency. Lormar S.r.l.'s reference requirements are therefore:

• the professionalism of the counterparty;
• the duly documented availability of means, including financial means, organised structures, capabilities and design resources, know-how, etc.;
• the existence and effective implementation of quality, safety and environmental management systems.

In contracting, procurement and, in general, the supply of goods and services, Lormar S.r.l.:

• applies, when selecting suppliers, the assessment criteria set out in existing procedures, objectively and transparently;
• does not prevent anyone with the required qualifications from competing to enter into contracts, adopting objective and documentable criteria when selecting candidates;
• complies with contractually agreed conditions;
• maintains open and frank dialogue with suppliers, in keeping with sound commercial practice.

In business relationships with customers and suppliers, payments, benefits (whether direct or indirect), gifts, and acts of courtesy or hospitality are prohibited, unless they are of such a nature and value that they do not compromise the Company's image and cannot be interpreted as intended to obtain preferential treatment not determined by market rules. In any case, any gifts, acts of courtesy or hospitality that go beyond what is normal must be reported and submitted to the decision of the Administrative Body.

An employee who receives gifts or preferential treatment from customers or suppliers that go beyond ordinary courtesy must immediately inform Management, who will, after appropriate checks, take the appropriate measures.

Entering into a contract with a supplier or customer and managing contacts with them are based on relationships of extreme clarity, avoiding, as far as possible, excessive mutual dependency.

To ensure maximum transparency and efficiency in the purchasing process, Lormar S.r.l. ensures:

• adequate traceability of the choices made;
• the retention of information, as well as contractual documents, for the periods established by applicable regulations.

With a view to bringing the procurement of goods and services into line with the relevant ethical-environmental principles, the Company may, for particular supplies, require social, environmental protection and workplace safety requirements. To this end, specific clauses may be included in individual contracts.

The Company also keeps, similarly to what happens with suppliers, a periodically updated customer register.

Lormar S.r.l. promotes and implements an efficient and constantly updated control system, which makes it possible to guarantee customers the quantity, quality, provenance and origin of the materials used in the production of its products.

Lormar S.r.l. considers issues relating to the environment and workplace safety to be of high importance.

To this end, in managing its business activities, the Company has adopted a system oriented towards safeguarding occupational health and safety and environmental protection, pursuing the continuous improvement of workplace health and safety conditions and respect for the environment.

Research and technological innovation are dedicated in particular to promoting products, activities and processes that are as compatible as possible with the environment and with the safety and health of operators.

Employees/collaborators, within the scope of their duties, participate in the process of risk prevention, environmental protection and the safeguarding of health and safety for themselves, their colleagues and third parties.

In particular, Lormar S.r.l., also through the active cooperation of its employees/collaborators, through a corporate safety assessment system, and by adhering to the provisions of the Risk Assessment Document:

• promotes and implements every reasonable initiative aimed at minimising risks and removing the causes that may endanger the safety and health of individuals, as well as jeopardise the integrity of the environment in all its aspects;
• pays continuous attention and commitment to improving its environmental performance, minimising negative environmental impact and making conscious and responsible use of natural resources;
• assesses in advance the impacts on the environment and on workers' health and safety of all new business activities and processes;
• cooperates with its stakeholders, both internal (e.g. employees) and external (e.g. institutions), to optimise the management of issues relating to Health, Safety and the Environment;
• maintains high standards of safety and environmental protection through the implementation of appropriate management and monitoring systems.

To this end, all employees/collaborators have successfully attended training and refresher courses on occupational health and safety, in accordance with the provisions of Legislative Decree 81/2008. Attendance certificates and diplomas are also kept by the Company.

Lormar S.r.l. is aware of the effects of its activities on the surrounding context, on economic and social development and on the general wellbeing of the community, and pays attention, in its conduct, to balancing these interests.

In particular, Lormar S.r.l. is committed to safeguarding, using the latest technology and scrupulously adhering to the procedures required by law, public health and the healthiness of places, people and products.

Lormar S.r.l. believes that dialogue with stakeholders is of strategic importance for the proper development of its business, and establishes, where possible, a stable channel of dialogue with associations representing its stakeholders, with a view to cooperating in the mutual interest of both parties.

Lormar S.r.l. refrains from making any contribution, direct or indirect, in any form, to parties, movements, committees, and political or trade union organisations, their representatives and candidates, except for contributions due under specific legal provisions.

Lormar S.r.l. looks favourably upon and, where appropriate, provides support for social and cultural initiatives aimed at promoting the individual and improving quality of life.

Relations with the press, the media and, more generally, external interlocutors must be maintained solely by persons expressly delegated to do so, in accordance with the procedures adopted by the Company.

Communications to the outside world follow the guiding principles of truthfulness, correctness, transparency and prudence, and are aimed at promoting knowledge of the Company's policies, programmes and projects.

Relations with the mass media are based on these principles and are reserved exclusively for the functions and responsibilities delegated to do so.

Employees/collaborators may not provide information to third parties, nor undertake to do so, without the authorisation of the competent functions.

Under no circumstances may employees/collaborators offer payments, gifts or other benefits intended to influence, or that could reasonably be interpreted as intended to influence, the professional activities of media personnel.

Relationships relating to the Company's activities with public officials or persons entrusted with public service duties (who act on behalf of central or local Public Administration, legislative bodies, European Union institutions, international public organisations or any foreign State), with the judiciary, with public supervisory authorities and other independent authorities, as well as with private partners holding public service concessions, must be undertaken and managed in absolute and strict compliance with the applicable laws and regulations, the principles set out in the Code of Ethics and in the internal protocols of the Model, so as not to compromise the integrity and reputation of either party. To this end, entering into commitments with Public Administrations and Public Institutions is reserved exclusively to the appointed and authorised functions, who will carry them out in due compliance with the law and the principles of the Code of Ethics and in full observance of the internal protocols set out in the Model.

Lormar S.r.l. prohibits its employees, collaborators or representatives and, more generally, all those who act in its interest, in their own name or on its behalf, from accepting, promising or offering, even indirectly, money, gifts, goods, services, benefits or undue favours (including in terms of employment opportunities) in connection with relationships with public officials, persons entrusted with public service duties, or employees in general of the Public Administration or other Public Institutions, or private individuals, in order to influence their decisions, with a view to obtaining more favourable treatment or undue benefits, or for any other purpose.

Any employee who directly or indirectly receives requests or offers of money or favours of any kind (including, for example, gifts of more than token value) improperly made to, or by, those who act on behalf of the Company in the context of relationships with public officials, persons entrusted with public service duties or employees in general of the Public Administration (Italian or foreign) or other Public Institutions, or with private individuals (Italian or foreign), must immediately report this to the Supervisory Body and to the relevant Administrative Management for the adoption of appropriate measures.

Any relationship with State or international institutions is therefore attributable exclusively to forms of communication aimed at explaining the Company's activities, responding to requests or parliamentary oversight measures (questions, interpellations), or otherwise making the Company's position known on relevant issues.

To this end, Lormar S.r.l.:

• operates, without any type of discrimination, through the communication channels designated for dealing with institutional interlocutors;
• represents its interests and positions in a transparent, rigorous and consistent manner, avoiding collusive conduct;
• avoids falsifying and/or altering reports or documentary data in order to obtain an undue advantage or any other benefit for the Company, and avoids allocating public funds to purposes other than those for which they were obtained.

It is the Company's policy to spread, at all levels, a culture characterised by awareness of the existence of controls and the adoption of a mindset oriented towards the exercise of control. The attitude towards controls must be positive, given the contribution they make to improving efficiency. "Internal controls" means all the tools necessary or useful for directing, managing and verifying the Company's activities with the aim of ensuring compliance with laws and procedures, protecting the Company's assets and the health/safety of individuals, managing activities efficiently, providing accurate and complete accounting and financial data, protecting consumers, and guaranteeing the quality of the products placed on the market.

The internal control system as a whole must reasonably ensure:

• compliance with applicable laws and the Code of Ethics;
• compliance with the Company's strategies and policies;
• the protection of the Company's tangible and intangible assets;
• the effectiveness and efficiency of management;
• the reliability of internal and external financial, accounting and management information;
• the effectiveness of the corporate responsibility policies adopted.

The responsibility for implementing an effective internal control system is shared at every level of the organisational structure; consequently, all collaborators, within the scope of the functions they perform, are responsible for the definition and correct functioning of the control system.

It is the task of the Supervisory Body to oversee the Code of Ethics; in particular, this body must (in addition to what is provided for under the Model):

• monitor the application of the Code of Ethics by the parties concerned, through the implementation of specific compliance programmes, and receive any reports provided by internal and external stakeholders;
• periodically report to the Administrative Body on the results of the activities carried out, flagging any significant violations of the Code;
• express opinions on the revision of the most significant policies and procedures, in order to ensure their consistency with the Code of Ethics;
• where necessary, propose a periodic review of the Code of Ethics.

Having received a final criminal conviction, or having been convicted by an irrevocable sentence involving the application of a penalty, constitutes grounds for ineligibility to serve on the SB.

The Code of Ethics is brought to the attention of all interested internal and external parties through dedicated communication activities, such as, by way of example, its delivery upon assuming the role of director or manager; upon signing an employment, agency or collaboration contract; as well as through publication of the Code of Ethics on dedicated company notice boards and online (intranet and internet).

In order to ensure correct understanding of the Code of Ethics, the Head of Personnel draws up and implements, also on the basis of any indications from the Supervisory Body for the Code, a periodic communication/training plan (on an annual or biennial basis) aimed at promoting awareness of the principles and ethical rules contained in the Code. Training initiatives may be differentiated according to the role and responsibility of collaborators.

The Company establishes communication channels through which interested parties can submit their reports regarding the Code or any violations thereof (reporting form). Alternatively, all interested parties may report, in writing and even anonymously, any violation or suspected violation of the Code of Ethics to the Supervisory Body, which will analyse the report, possibly hearing from the author and the person responsible for the alleged violation. The Supervisory Body acts in such a way as to protect whistleblowers against any type of retaliation, understood as any act that could give rise, even merely to the suspicion, of being a form of discrimination or penalisation. The confidentiality of the whistleblower's identity is also guaranteed, subject to legal obligations.

In the event of an established violation of the Code of Ethics, the Supervisory Body reports the matter, together with any suggestions deemed necessary, to the Administrative Body, through the procedures adopted by the Company for reporting all non-conformities (reporting form) and violations relating to this Code, the Model, and the procedures contained therein. Where such violations concern the directors themselves, the Supervisory Body will report the matter to the Shareholders' Meeting.

The relevant functions, activated by the bodies referred to above, determine the measures to be adopted in accordance with applicable regulations, oversee their implementation, and report the outcome to the SB.

Violation of the principles set out in the Code of Ethics and in the procedures provided for by the internal protocols of the Model undermines the relationship of trust between the Company and its directors, employees, consultants, collaborators of any kind, customers, suppliers, and commercial and financial partners. In particular, compliance with the provisions of this Code of Ethics, as well as with the procedures contained in the Model, must be considered an essential part of employees' contractual obligations, pursuant to Article 2104 of the Italian Civil Code, such that violation of these provisions may constitute a breach of the obligations of the employment relationship and/or a disciplinary offence, in accordance with the procedures under Article 7 of the Workers' Statute and the applicable collective bargaining agreement.

Compliance with this Code of Ethics is an integral part of the contractual obligations assumed by other recipients (directors, representatives, suppliers, etc.), with the consequence that any violation of the provisions contained herein or of the procedures provided for by the Model may be considered a breach of contract, with all legal consequences, such as termination of the contract or assignment, as well as compensation for damages.

Such violations will therefore be pursued incisively and promptly by Lormar S.r.l., through the disciplinary measures provided for in the Model, in accordance with the provisions of Article 7 of the Workers' Statute and the applicable collective agreements, in a manner that is adequate and proportionate, regardless of any criminal relevance of such conduct and regardless of whether criminal proceedings are initiated in cases where such conduct constitutes an offence.

The effects of violating the Code of Ethics and the procedures set out in the Model must be taken seriously by all those who, in any capacity, have dealings with Lormar S.r.l.: to this end, the Company disseminates the Code of Ethics and internal procedures, and provides information on the sanctions provided for in the event of violations and on the methods and procedures for imposing them.

This Code of Ethics is adopted by the Administrative Body. Any amendments and/or updates thereto will be approved by the same Administrative Body and promptly communicated to recipients.