Adoption of the Organizational, Management and Control Model by Innovery S.p.A Lgs. Decree no. 231/2001

In accordance with compliance with Legislative Decree 231, the Organization and Control Model, as well as the Code of Ethics are applied to all the Italian companies of the group; the same principles are adopted in the Code of Ethics regarding oher Companies to  have a complete harmonization of values.

The Model consists of:

• General Part: in addition to the Decree, it illustrates the responsibilities and structure of the Model, as well as training, its dissemination, the Supervisory Body and the disciplinary system;

• Code of Ethics: explains the fundamental principles of the corporate culture, the reference values and the concrete rules of conduct towards all internal and external subjects, who have a direct or indirect relationship with the companies of the Innovery S.p.A.

In order to control the effectiveness and compliance with the Model, as well as to ensure its constant updating and to ensure an adequate disclosure to internal and external supervisory bodies, Innovery S.p.A. has a Supervisory Body, appointed by the Board of Directors. The Organizational and Control Model, as well as the Code of Ethics, are applied to all the group’s entities, from a complete harmonization of values and regulations perspective.

Policy for the Prevenction of Corruption

Innovery is fully aware that the phenomenon of corruption is a major obstacle to the economic, political, and social development of a country and a heavy distortion of the rules, fairness and transparency of markets.

Senior management at Innovery prohibits corruption and is fully committed to ensuring actions and behavior based exclusively on criteria of transparency, fairness and moral integrity, which prevent any attempt at corruption on the part of all resources involved.

Policy for Corporate Social Responsibility

Innovery pursues and upholds respect for internationally affirmed human rights and considers the protection of the integrity, health, rights and welfare of its employees, and the environment as primary and fundamental elements in the exercise and development of its activities.