Summary

Introduction
Relationship with Stakeholders
The Value of Reputation in Corporate Credibility
The contents of the Code of Ethics
Contractual value of the Code of Ethics
Code of Ethics Updates
1.2 General Principles
1.3 The Corporate Governance System
1.4 The internal control system
1.5 Relations with the Staff
1.6 Participation in tenders and relationships with clients
1.7 Relations with suppliers
1.8 Relations with administrative authorities
1.9 Relations with local reference bodies and other regulatory authorities
1.10 Relations with political parties, trade unions and associations
1.11 The methods of implementation and control of the Code of Ethics

Introduction

This Code of Ethics is a public declaration of the Antica Sartoria Srl Company, which identifies the general principles and rules of conduct which are recognized as having a positive ethical value.

As an element of application of the provisions of Article 6 of Legislative Decree 8 June 2001, n. 231, the Code of Ethics integrates the regulatory framework to which the Institution is subject.

The purpose of this Code is to ethically guide the actions of the Antica Sartoria Srl Company and its provisions are consequently binding on the behavior of all the Company's Directors, employees, consultants and anyone who establishes, in any capacity, a collaborative relationship with it.

The Code is widely disseminated internally through suitable means and is made available to any interlocutor of the Company. The Company Antica Sartoria Srl also undertakes to recall compliance with the provisions of this Code in all economic relationships established by it.

Relationship with Stakeholders

The Code intends, in particular, to direct the conduct of the Company Antica Sartoria Srl towards cooperation and trust towards stakeholders, that is, all public or private entities, be they individuals, groups or institutions, whose contribution is necessary for the achievement of the corporate mission and/or whose interests are directly or indirectly influenced by the Company's activities.

The Value of Reputation in Corporate Credibility

Reputation and credibility are fundamental intangible resources that favor member investments, relationships with local institutions, the development of human resources and the correctness and reliability of suppliers.

The contents of the Code of Ethics

The Code of Ethics consists of:

• from the general ethical principles that identify the reference values ​​in company activities;
• from the criteria of conduct towards each stakeholder, which provide the guidelines and rules to which the recipients of the Code are required to adhere;
• from the implementation mechanisms that outline the control system for the correct application of the Code of Ethics and for its continuous improvement.

Contractual value of the Code of Ethics

Compliance with the provisions of the code must be considered an essential part of the contractual obligations of employees, collaborators and partners of the company Antica Sartoria Srl

Code of Ethics Updates

By resolution of the Administrative Body, the Code may be modified and integrated, also on the basis of suggestions and observations of the Supervisory Body.

1.2 General Principles

Legality

The Società Antica Sartoria Srl has as an essential principle the observance of laws and regulations in force in Italy and in all the countries in which it operates and the respect of the democratic order established therein. The recipients of the Code are required to comply with the legislation in force. In no case is it permitted to pursue or realize the interest of the Società Antica Sartoria Srl in violation of the laws.
Antica Sartoria Srl is committed to ensuring that interested parties receive an adequate information and ongoing training program on the Code of Ethics.

Transparency

The principle of transparency is based on the truthfulness, accuracy and completeness of information both outside and inside the company Antica Sartoria Srl

The Correctness

The principle of fairness implies respect for rights, including those relating to privacy and opportunities, as well as for the laws in force aimed at protecting the individual personality of all those involved in their work and professional activity.

This also requires the elimination of any discrimination and any possible conflict of interest between those who in any capacity provide their services and the Antica Sartoria Srl Company.

The Efficiency

The principle of efficiency requires that each work activity be carried out according to the principles of economy in the management of the resources used in the provision of services and that the commitment be made to offer an adequate service with respect to the needs of the customer and according to the most advanced standards.

The Spirit of Service

The principle of the spirit of service implies that each recipient of the Code is always oriented, in their behavior, towards sharing the corporate mission aimed at providing a service of high social value and utility to the community, which must benefit from the best quality standards.

The Competition

The Antica Sartoria Srl Company intends to develop the value of competition by adopting principles of correctness, fair competition, transparency towards all operators present in the market.

Relations with the community and environmental protection

Società Antica Sartoria Srl is aware of the impact of its activities on the economic and social development and quality of life of the reference territory.

For this reason, in carrying out its activities, the Company is committed to safeguarding the surrounding environment and contributing to the sustainable development of the territory.

Cultural Heritage

The Company recognizes that the protection and enhancement of cultural heritage, as established by the Italian Constitution, contribute to preserving the memory of the national community and its territory and to promoting the development of culture. To this end, to the extent of its competence and within the limits of its powers, it undertakes to guarantee its conservation in compliance with the applicable legislation in force.

The valorization of human resources

Human resources represent a fundamental factor for the development of the Antica Sartoria Srl Company, therefore, the Company protects and promotes their professional growth.

1.3 The Corporate Governance System

The governance system adopted by Società Antica Sartoria Srl complies with current legislation and is aimed at ensuring the maximum and most balanced collaboration between its components through a harmonious balance of the various management, direction and control roles.

This system is aimed at ensuring responsible and transparent management of the company towards the market, with a view to creating value for members and pursuing social and environmental objectives defined in agreement with the relevant local authorities.

The members of the corporate bodies must base their activities on the principles of correctness and integrity, refraining from acting in situations of conflict of interest within the scope of the activity they carry out in the Company.

The members of the bodies are also required to behave in a manner inspired by the principles of autonomy, independence and respect for the guidelines that the Company provides in the relationships that they maintain, on its behalf, with public institutions and with any private entity.

Their assiduous participation in the Company's activities is required; they are required to make confidential use of the information they become aware of for reasons of office and cannot take advantage of their position to obtain personal advantages, whether direct or indirect; all communication activities must comply with the laws and conduct practices and must be aimed at safeguarding sensitive information and industrial secrets.

Members of the company's bodies are required to comply with current legislation and the principles contained in this Code.

The obligations of loyalty and confidentiality bind such subjects even after the termination of the relationship with the company Antica Sartoria Srl.

Due to its activities and organizational complexity, Antica Sartoria Srl adopts a system of delegation of powers and functions that provides, in explicit and specific terms, the assignment of tasks to persons with suitable capacity and competence.

1.4 The internal control system

In compliance with current legislation and with a view to planning and managing company activities aimed at efficiency, correctness, transparency and quality, the Company Antica Sartoria Srl adopts organizational and management measures suitable for preventing illicit behavior or behavior that is in any case contrary to the rules of this Code by any person acting for the Company.

To this end, in terms of internal control, the company adopts a specific system aimed at verifying the exact application of the organizational and management models used, compliance with internal and external regulations, and the adequacy of accounting principles and records.

The Administrative Body periodically verifies the adequacy and effective functioning of the internal control system and carries out the interventions deemed necessary or appropriate to ensure its best functioning.

In order to verify and apply the provisions contained in this Code, a specific Supervisory Body has also been established which assists the Administrative Body in establishing and updating the guidelines of the internal control system, in assessing the adequacy and effective functioning of the same and in the analysis of company risks and carries out the additional tasks subsequently indicated in this Code.

1.5 Relations with the Staff

Società Antica Sartoria Srl recognizes the value of human resources, respect for their autonomy and the importance of their participation in the company's activities. The management of the employment relationship, pursuing an organization by objectives, is oriented to favor the professional growth and skills of each employee also in relation to the application of incentive tools.

Any discrimination based on race, sex, nationality, religion, language, trade union or political affiliation in hiring, remuneration, promotion or dismissal, as well as any form of favoritism, is prohibited.

Antica Sartoria Srl is committed to protecting the moral and physical integrity of its employees, consultants and customers.

To this end, it promotes responsible and safe behavior, adopts all the safety measures required by technological evolution to guarantee a safe and healthy working environment, in full compliance with the current legislation on prevention and protection pursuant to Legislative Decree 81/2008.

Antica Sartoria Srl is committed to ensuring compliance with the conditions necessary for the existence of a collaborative and non-hostile working environment and to preventing discriminatory behavior of any kind.

The collaboration of all is required in order to maintain a climate of mutual respect for the dignity, honor and reputation of each person.

Employees who believe they have suffered discrimination may report the incident to the Supervisory Body, which will proceed to ascertain whether the Code of Ethics of Conduct has actually been violated.

Without prejudice to the obligations arising from the provisions in force, the selection of personnel is subject to verification of the full compliance of the candidates with a substantial adherence to the professional profiles required by the company, in compliance with equal opportunities for all interested parties.

The hiring of personnel takes place on the basis of regular employment contracts, and no form of employment relationship that is not compliant or in any case evasive of current legislation is permitted.

The staff undertakes to comply with the obligations set forth in this Code and must, in carrying out their duties, comply with the law and base their conduct on the principles of integrity, correctness, loyalty and good faith. Those entrusted with the task of keeping accounting records are required to carry out each entry in an accurate, complete, truthful and transparent manner and to allow any checks by persons, including external ones, appointed for this purpose.

Accounting evidence must be based on accurate and verifiable information and must fully comply with internal accounting procedures.

Each document must allow for the reconstruction of the related transaction and must be accompanied by adequate documentation.

All actions concerning the activity of the company Antica Sartoria Srl must be recorded in adequate records that allow for checks and controls on the decision-making, authorization and execution process.

Anyone who becomes aware of any omissions, errors or falsifications is required to notify the Supervisory Body.

Anyone who works, in any capacity, for the Antica Sartoria Srl Company must maintain a position of autonomy and integrity in order to avoid making decisions or carrying out activities in situations, even if only apparent, of conflict of interest with respect to the activity of the Company itself.

Any activity that conflicts with the correct fulfillment of one's duties or that may harm the interests and image of the Antica Sartoria Srl Company must be avoided.

Any situation of conflict of interest, real or potential, must be communicated in advance to the person in charge who, according to the established methods, will inform the Supervisory Body.

The employee uses and carefully safeguards the assets available to him for office reasons.

Any improper use of the Company's property is not permitted.

Each employee is directly and personally responsible for the protection and legitimate use of the assets and resources entrusted to him for the performance of his duties.

The company Antica Sartoria Srl, in compliance with the laws in force, adopts the necessary measures to prevent distorted uses of the same.

With respect to the use of information systems, each employee is responsible for the security of the systems used and is subject to the regulatory provisions in force and the conditions of the license agreements.

Except as provided by civil and criminal law, the use of network connections for purposes other than those related to the employment relationship or to send offensive messages or messages that may damage the image of the company Antica Sartoria Srl is considered improper use of company assets and resources.

Each employee is also required to make the necessary commitment in order to prevent the possible commission of crimes through the use of IT tools.

The employee may not ask for, for himself or for others, gifts or other benefits, nor accept the latter, except those of modest value or in accordance with normal commercial and courtesy practices, from anyone who has benefited or who may benefit from the activity of the Antica Sartoria Srl Company.

The employee may also not offer gifts or other benefits to any person from whom he may acquire preferential treatment in the conduct of any activity connected to the Antica Sartoria Srl Company.

No illicit advantages may be attributed to public or private customers or suppliers.

Gifts and benefits offered but not accepted, which exceed a modest value, must be reported to allow for an adequate assessment by the person in charge, who will inform the Supervisory Body.

This rule does not allow for exceptions even in those countries where offering valuable gifts or other benefits is customary.

The Company Antica Sartoria Srl protects the privacy of the personal data processed, in compliance with the regulations in force on the matter, believing that the protection of personal data is an essential value, the employee is required to keep confidential the information learned in the exercise of his functions in accordance with the law, regulations and circumstances.

The employee must observe this duty of confidentiality even after the termination of the employment relationship, ensuring that the obligations set forth by current privacy legislation are respected.

All employees are required to promptly and confidentially report to their manager and/or to the Supervisory Body any information they become aware of in the course of their work, regarding violations of legal provisions, the Code of Ethics of conduct or other company provisions that may, in any capacity, involve the Company Antica Sartoria Srl

Managers must monitor the work of their employees and must inform the Supervisory Body of any possible violation of the aforementioned rules.

The above provisions are also applicable to collaborators, agents, consultants and representatives of the Company.

1.6 Participation in tenders and relationships with clients

In participating in competitive comparison procedures, the Company Antica Sartoria Srl carefully evaluates the appropriateness and feasibility of the requested services, with particular attention to the regulatory, technical and economic conditions, promptly reporting any anomalies where possible and in no case assuming contractual commitments that could put the Company in the position of having to resort to unacceptable savings on the quality of the service, on personnel costs or on workplace safety.

In its relations with clients, Antica Sartoria Srl ensures correctness and clarity in commercial negotiations and in the assumption of contractual obligations, as well as their faithful and diligent fulfillment.

1.7 Relations with suppliers

The methods of selecting the supplier must comply with the current regulations and the internal procedures of the company established for this purpose.

The choice of supplier and the purchase of goods and services of any kind must take place in compliance with the principles of competition and equal conditions of the presenters of the offers and on the basis of objective assessments relating to the competitiveness, quality, usefulness and price of the supply, as well as in compliance with the principles of legality.

Relations with the Company's suppliers, including financial and consultancy contracts, are governed by the provisions of this Code and are subject to constant and careful monitoring by the Company, including with regard to the appropriateness of the services or goods supplied with respect to the agreed consideration.

The Company establishes appropriate procedures to ensure maximum transparency in supplier selection and purchasing operations for goods and services through a documentation system of the entire selection and purchasing procedure that allows the reconstruction of each operation.

The Company undertakes to inform the supplier in a correct and timely manner regarding the characteristics of the activity, the forms and times of payment in compliance with the regulations in force as well as the expectations of the counterparty, given the circumstances, the negotiations and the content of the contract.

The performance of the contractual obligations by the supplier shall comply with the principles of fairness, correctness, diligence and good faith and shall take place in compliance with the applicable legislation.

The Company undertakes to promote, within the scope of its procurement activities, respect for environmental conditions and to ensure that it is carried out in compliance with ethical principles by requiring, for particular supplies and services, requirements of social relevance.

The company Antica Sartoria Srl pursues the objectives indicated by the relevant Public Institutions and collaborates effectively with the bodies of the same responsible for the regulation and control of local public services.

The Company pursues these objectives by combining them with its mission and with the need for organizational and managerial autonomy typical of any economic operator.

1.8 Relations with administrative authorities

In order to ensure maximum clarity in institutional relations, these are maintained exclusively through referents who have received an explicit mandate from the corporate bodies and who are not in situations of conflict of interest with respect to the representatives of the institutions themselves.

Gifts or acts of courtesy and hospitality towards government representatives, public officials and public employees are permitted to the extent that their modest value does not compromise the integrity, independence and reputation of one of the parties.

In any case, this type of expenditure must be authorised and documented appropriately.

1.9 Relations with local reference bodies and other regulatory authorities

During a business negotiation or commercial relationship with the Public Administration, no actions should be taken, directly or indirectly, that could propose employment and/or commercial opportunities from which advantages derive, for oneself or for others, to employees of the Public Administration, or to their relatives or in-laws.

In the event that Antica Sartoria Srl is represented by a “third party” in its relations with the Public Administration, the same directives valid for the Company itself shall apply to the consultant and his staff.

1.10 Relations with political parties, trade unions and associations

Società Antica Sartoria Srl does not contribute in any way to the financing of political parties, movements, committees and political and trade union organizations, their representatives and candidates, outside of the cases provided for by specific regulations.

1.11 The methods of implementation and control of the Code of Ethics

The Supervisory Body is entrusted with the task of supervising the implementation and compliance with this Code and the organizational and management models, their effectiveness, adequacy and ability to maintain the functionality and solidity requirements required by law over time.

The Supervisory Body is guaranteed autonomy and independence, as well as adequate resources to carry out the tasks assigned to it.

All interested parties, internal and external, are required to report verbally or in writing (with respect to the nature of the violation) and in a non-anonymous form any non-compliance with this Code and any request for violation of the same, from whomever it may come, to the Supervisory Body.

Società Antica Sartoria Srl guarantees that the reports reach the Supervisory Body and undertakes to protect the authors of the reports against any retaliation they may face for having reported incorrect behavior, obliging itself to keep their identity confidential, without prejudice to legal obligations.

Whistleblowing: The Company complies with the principles of whistleblowing adopted, using the systems made available to it by the legislation and made known externally.

Serious and persistent violations of the provisions of the Code of Ethics by its recipients damage the relationship of trust established with the Company Antica Sartoria Srl and may lead to the imposition of disciplinary sanctions, compensation for damages and, in cases of serious breach, termination of the employment relationship.

For the purposes of this Code, the term “serious breaches” refers to all persistent breaches of the Code which may result in sanctions against the Company.

With respect to employees, compliance with the provisions of the Code of Ethics is an essential part of the contractual obligations pursuant to and for the purposes of Articles 2104, 2105 and 2106 of the Civil Code.

The sanctioning system must comply with the provisions of Law No. 300 of 20 May 1970, specific sector regulations, where they exist, collective bargaining and company disciplinary codes.