Model 231

The aim of the “Organisation, Management and Control Model” (hereinafter also the “Organisational Model”) is to free the Green Network Group of administrative responsibility in the event of crimes committed pursuant to Leg. Decree 231/2001 by company partners, directors, employees or, in general, consultants.

The specific goal is to optimise the company control system in order to respect the provisions of Leg. Decree 231/2001 and therefore:

• establish the conditions for the prevention of the crimes, avoiding fines and penalties;

• avoid, in any case, unsuitable and unethical behaviour in relations with the local authorities and all interested parties on the part of those that work at Green Network (Managers, Employees) and those who work for Green Network (suppliers, partners etc).

The Organisational Model is applied to all internal and external company process areas and Green Network’s organisational structures.

Green Network’s subsidiaries, not explicitly indicated above, must respect the Code of Ethics in full and adjust or develop their own organisation, management and control model in line with the ethical principles and protocols defined by the sub-holding.