Ethical Policy

NOTICE OF ACCEPTANCE OF THE COMPLIANCE MODEL AND APPOINTMENT OF THE COMPLIANCE COMMITEE

Giovanni Bozzetto S.p.A., on December 17, 2013 approved a compliance model (hereinafter, the “Compliance Model”) and appointed the compliance committee (hereinafter, the “Compliance Committee”) in accordance with legislative decree 231/2001.

Legislative decree 231/2001 has introduced in the Italian legal system the liability of private entities for certain crimes committed in the interest or to the advantage of the entity by any subject which is in relation with it. Therefore, nowadays, the entity can also be judged by criminal Courts, which may convict it with pecuniary or afflictive punishments, for example the disqualification or the prohibition to contract with Public Administration.

Pursuant to legislative decree 231/2001 the entity may avoid punishment if proves the acceptance of the Compliance Model and the appointment of the Compliance Committee, whit the specific assignment to verify the observance of the Compliance Model and its proper implementation.

Giovanni Bozzetto S.p.A., by the approval of the Compliance Model pursues not only the full compliance to the domestic law, but takes also the opportunity to point out which are the commercial policies and the values that inspire Company’s activity; in particular, business ethics and respect of legality in all the areas; considering the Compliance Model as an internal handbook for crimes’ risks prevention.

Thus, Giovanni Bozzetto S.p.A. wants to offer to any person or entity which gets in contact with itself a rulebook of essential and unavoidable principles.

The Compliace Committee represents the instrument available to any subject which aims to point out dysfunctions or anomalous conduct.

The recipients of the Compliance Model are all the subjects which effectively take part to company’s activity. All of them must follow and respect its rules: managers, directors, statutory auditors, employees, partners, suppliers, advisors and freelancers.

A paper copy of the Code of Conduct is available at the Company’s Headquarters and it can be also consulted at the link given at the bottom of this communication. At the “Notification” menu, you shall find specific procedure to contact the Compliance Committee.

Giovanni Bozzetto S.p.A.