Code of Ethics and Model 231

Code of Ethics

Unimatica's Code of Ethics defines the ethical principles, responsibilities and essential rules of conduct in the conduct of business and company activities assumed by Unimatica, its collaborators and all persons involved directly or indirectly in the company's activities.

The Code of Ethics constitutes a fundamental element of the set of internal rules and procedures adopted by Unimatica for the implementation of the regulations set forth in Legislative Decree No. 231 of June 8, 2001, as amended and supplemented on the subject of the administrative responsibility of Companies.

Model of organization, management and control (MOG)

On June 8, 2001, Legislative Decree No. 231 was issued by which the Legislature adapted Italian legislation to international conventions on the liability of legal persons. The Decree establishes the administrative liability of the company in the event that certain types of offenses are committed in the interest or to the advantage of the company by persons in top positions or by persons placed under the direction or supervision of the former. The Company's liability is in addition to that of the individual who materially committed the offense and is independent of it.

Unimatica, in full compliance with its own policies, has therefore proceeded to define and implement the Model of Organization, Management and Control (hereinafter MOG) required by Legislative Decree 231/2001, in the belief that this constitutes not only a valid tool for raising the awareness of all those who work on behalf of the Company, so that they behave correctly and straightforwardly, but also a more effective means of prevention against the risk of committing the crimes and administrative offenses provided for by the reference legislation. In preparing the MOG, account was first taken of existing regulations, the Code of Ethics, procedures and control systems already in place and already operating in Unimatica, as they are also suitable as measures to prevent crimes and unlawful conduct in general, including those provided for in the Decree.

The MOG consists of a structured and organic system of rules and procedures, as well as control activities, to be carried out also on a preventive basis, aimed at preventing the commission of the different types of offenses covered by the Decree.

Unimatica's MOG, updated in accordance with developments in Legislative Decree 231, is available to those entitled to it upon special request sent to the company as defined in the Contacts section of this website.

Unimatica's Anti-Corruption Policy

Defines Unimatica's commitment to the principles of prevention of Corruption, as well as its Organization and Management Model pursuant to Legislative Decree No. 231/2001.

Whistleblowing

In compliance with the new Legislative Decree 24/2023, which transposes into Italian law the EU legislation protecting individuals who report illegal activities or fraud within a public or private organization, so-called "Whistleblower", Unimatica has revised its system for handling reports, including anonymous ones, and updated the whistleblowing procedure available below.

The following may constitute the subject of Whistleblowing:

• of Unimatica's Code of Ethics and Anti-Corruption Policy,
• of laws, acts having the force of law or applicable national and European Union regulations;
• of Unimatica's internal procedures and regulations,
• of Unimatica's Model 231 capable of causing unlawful advantage or damage or harm, even if only of image, to the company.