GCF: Code of Ethics

Governance

Code of Ethics

Organisational model pursuant to Legislative Decree 231/2001

The image and reputation that the Group companies have built over more than 70 years of history stem from compliance with the principles and standards of conduct that inspire and guide the daily actions of individual stakeholders and of the Group companies themselves.

Since its inception, the Group has progressively strengthened the integration of sustainability principles into its strategy and corporate governance, promoting a culture based on legality, transparency, responsibility and respect for rights. To this end, the Organisation, Management and Control Model pursuant to Legislative Decree 231/2001 has been adopted.

The Code of Ethics - the fundamental value-based cornerstone of the Organisational Model (MOG) - is a governance system, a framework for implementing ethical principles, and an organic body of corporate values, principles and standards of conduct. It reminds everyone that actions and decisions are grounded in shared values: the corporate culture.

Adopted on 2 July 2020 and subsequently updated to incorporate the latest legislative developments, it sets out the behavioural guidelines that directors, managers, employees and collaborators of GCF and Gefer - as well as of the other Group companies - must follow within the scope of their respective roles and activities.

With the aim of fostering an increasingly respectful and socially responsible attitude within the company and establishing a relationship of trust and transparency with stakeholders, the Code of Ethics promotes the dissemination of six general principles.

• Responsibility: The company’s interests must be pursued in compliance with applicable laws.

• Fairness: It is essential to eliminate any conflict of interest between employees and the Company, while respecting the rights of all parties involved in work-related and professional activities.

• Transparency: Truthfulness, accuracy and completeness of information, both internal and external, are fundamental principles for the Company.

• Efficiency: In every work activity, the principle of efficiency must be observed, with the aim of managing resources economically and providing services that adequately meet customers’ needs.

• Service-mindedness: Every recipient of the Code of Ethics must align their conduct with the company’s mission, basing their actions on the principle of service.

• Competition: The Company operates according to principles of fairness, loyal competition and transparency towards all competitors.

The Code of Ethics is complemented by a Disciplinary Code, which forms an integral part thereof and establishes a detailed system of sanctions, reinforcing its binding nature as well as its guidance function. The implementation and observance of the Code of Ethics and of the Organisation, Management and Control Model adopted by the Company are supervised by a Supervisory Body (established pursuant to Article 6, paragraph 1, letter b of Legislative Decree 231/2001) which, endowed with autonomy and independent decision-making powers, operates on a continuous basis.

The Code expresses shared principles, values and responsibilities: it is disseminated throughout all corporate levels and shared with customers, suppliers and consultants so that everyone may become aware of the ethical vision of the Group companies and be inspired by and comply with the same principles. A training module dedicated to Legislative Decree 231/2001 and to the General Section of the Organisational Model has been made available to all personnel through the corporate e-learning platform. Furthermore, specific in-depth training programmes have been launched for operational staff working in particularly sensitive managerial areas.

By defining principles relating to business relationships, competition, health, safety and the environment, the Code incorporates values consistent with the United Nations Sustainable Development Goals (SDGs) and outlines the boundaries of a corporate style based on behavioural standards that should inspire actions and which all employees are required to observe in workplace interactions within the Group companies, in relationships with suppliers and partners, and in dealings with public officials and institutions.