TABLE OF CONTENTS

THE INSPIRING PRINCIPLES OF OUR BUSINESS ETHICS

1. Introduction
2. Recipients, scope of application and updating
3. Respect and enhancement of human resources
   • Basic principles
   • Development of professionalism
4. Internal relationships
   • Rules of conduct for staff
   • Privacy compliance
5. External relationships
   • Relations with public administration
   • Customer and supplier relationships
   • Gifts, benefits and promises of favours
6. Use and protection of business assets
7. Conflict of interest
8. Use and disclosure of Information
9. Transparency in accounting
   • Accuracy and transparency of official documentation
   • Registration and documentation of transactions
   • Accounting transparency
10. Health protection and safety
11. Environmental protection
    • Notification of violations (whistleblowing)
12. Obligations on informing
13. Sanction system

THE INSPIRING PRINCIPLES OF OUR “BUSINESS ETHICS”

This Code regulates the set of duties and responsibilities that the company expressly undertakes towards all stakeholders with whom it interacts in carrying out its business.

The term, stakeholders, encompasses all employees, collaborators, suppliers, customers, local communities, institutions and associations and society as a whole.

Alongside its commitment, the company requires that the set of ethical principles and values expressed in the Company Ethics inspire the activity of everyone who works in the company, taking into account the importance of roles, the complexity of functions and the entrusted responsibilities for the pursuit of corporate objectives.

The behaviour prescribed in the Business Ethics is automatically extended to all employees, collaborators, directors and statutory auditors, who are required to have complete good faith in the execution of the tasks entrusted to them and to apply the ethical principles and values of the Business Ethics in all activities carried out on behalf of Petroltecnica, avoiding conflicts of interest both in employment relationships and in the performance of their activities.

Service providers, contractors and partners are required to comply with workplace health and safety and environmental regulations applicable to our operations and are likewise formally invited to comply with ethical standards.

Any third party who has an interest in speaking and interacting with the company will be provided with this Code to adapt their work and attitude, as far as their competence and pertaining to the principles of the Ethics are concerned.

Petroltecnica undertakes to disseminate this Code to all stakeholders, to periodically update it that takes into account internal and external changes, to make available any tool that favours its full application, to carry out checks to news concerning violations of the rules of Business Ethics, to the evaluation of the facts and its consequent implementation, in the event of an ascertained violation, of adequate sanctions, where applicable.

In pursuit of the corporate purpose, Petroltecnica guarantees the protection of the health and safety of employees and collaborators, the competence of operators in the environmental field, the ability to promptly prevent more serious consequences following polluting events, safety for the community and environment, the quality of the interventions supported by the use of innovative technologies with a limited environmental impact, in compliance with all applicable national and international laws and regulations.

Petroltecnica’s investment strategies and consequent operational conduct are oriented towards these purposes.

Petroltecnica’s corporate nature makes it naturally inclined to pursue objectives of profit and development.

To this end, Petroltecnica believes that healthy economic development cannot exist for a company or a territory if the right attention is not paid by the economic subjects to the needs of society.

For this reason, Petroltecnica acts so that three fundamental and essential factors can coexist within its own profit: economic growth, environmental protection, social intervention, according to the principle according to which the global performance of a company must be measured through an integrated reporting of following dimensions:

1. economical
2. social
3. environmental

This triple approach is one of the principles of Corporate Social Responsibility that Petroltecnica adheres to. It is defined by the European Commission as “voluntary integration of the social and ecological concerns of companies in all commercial operations, in the decision-making processes and the relationships between the company and its interlocutors”.

To achieve these objectives, Petroltecnica intends to implement, strengthen and strive to continuously pursue the following strategies:

• Rooted in the territorial community
• Business climate/li>

• Economic autonomy

A) Rooted in the Petroltecnica territorial community

• It is aware that its own well-being and economic development are inextricably linked to the well-being and economic development of the local community of reference;
• It considers a continuous interaction with the community, individuals, schools, universities, institutions, local authorities and associations present in the area is fundamental, through diversified initiatives that include environmental education programmes, the establishment of awards and competitions dedicated to the environment, support for culture, arts and urban planning of the reference area, support for the world of scientific and academic research in the areas of competence of Petroltecnica;
• It also believes that it is essential to make the inside known to the outside world through initiatives for the presentation and opening of its factories and plants;
• It believes in solidarity and corporate social responsibility that it manifests through an ad hoc structure made up of employees and collaborators of Petroltecnica called the Solidarity Pool which mainly moves along three lines: Environment, Peace, Solidarity;
• It is aware of the importance that the environment and its protection have for all the people who currently inhabit the planet and for generations. It is aware of the public purpose and the importance of its activities for the safety of the community as well as the role that its activity can affect the conditions, economic and social development and general well-being of the community;
• It contributes to the safety of the community where it operates through the use of innovative and environmentally-friendly equipment for the provision of efficient and technological services

B) Petroltecnica business climate

• It recognises the centrality of human resources in the search for success factors;
• It is committed to ensuring that workers have guaranteed all their rights with respect and dignity;
• It employs resources in the research of technologies with limited environmental impact and the highest level of safety guarantee for the workers involved;

• It protects and supports the needs of working mothers;
• It protects and enhances human resources through the enhancement and care of moments in the private life of employees and/or collaborators who are given particular attention;
• It undertakes to disseminate and encourage socialisation initiatives between employees and collaborators within the company;
• It undertakes to take care of motivating its employees and collaborators through the organisation of prizes and competitions that stimulate creativity and active participation in corporate problem-solving processes;
• It considers the growth of human resources to be fundamental through continuous training that is attentive to the specific needs of each sector and professionalism in a reasoned, shared and programmed and personalised manner;
• It undertakes to train its resources to share the principles of Business Ethics and facilitate compliance with them at all levels;
• It intends to evaluate the personnel to be hired based on the correspondence of the candidates’ profiles with those expected and the company needs in compliance with equal opportunities for all interested parties;
• It undertakes, with activities that go beyond the provisions of the law, to guarantee the physical and moral integrity of its collaborators, working conditions that respect personal dignity, healthy and safe work environments and the introduction of prevention and protection devices ad hoc;
• It manages with the utmost confidentiality personal data, sensitive and otherwise, and the information provided by its employees and the natural and/or legal persons with whom it has relationships or does business with. Where required, the processing of data is carried out with the consent of the interested parties, expressed following the law, and takes place in the manner and within the limits required by Legislative Decree no. 196/2003.
• Within the External Relations – Training and Personnel Development Development, it provides for the task of monitoring the correct application of Business Ethics in the various functions and constitutes the interface between the Management and the Solidarity Pool. The Solidarity Pool is a free and voluntary membership structure made up of Petroltecnica employees and collaborators who intend to take action in the field of voluntary work or social solidarity, which annually manages a budget consisting of a percentage of Petroltecnica’s revenues destined for financing and support development cooperation initiatives, support for local and international associations. The Solidarity Pool mainly moves along three lines:

• Environment
• Peace
• Solidarity

C) Economic autonomy

Petroltecnica believes that operators institutionally responsible for financing industrial and commercial initiatives reduce the horizon of evaluations to those of a strictly financial nature which, although fundamental, do not exhaust the spectrum of values in the field and are conditioning for corporate decisions.

INTRODUCTION

Petroltecnica believes that compliance with ethical rules and transparency in the conduct of business are a necessary condition, as well as a competitive advantage, to pursue and achieve its objectives.

To this end, Petroltecnica promotes the creation of an environment characterised by a strong sense of ethical integrity, in the firm belief that this contributes decisively to the effectiveness of policies and control systems, influencing behaviour that could escape even the most sophisticated supervisory mechanisms.

Petroltecnica has deemed it appropriate and necessary to adopt and issue a Code of Ethics that expresses the values which must be based on the conduct of all those who, at various levels of responsibility, contribute with their acts to the performance of its business, including consultants and/or external collaborators however named.

These values are mainly:

• moral integrity, personal honesty and correctness in internal and external relationships;
• transparency towards related stakeholders and the market;
• respect for employees and the commitment to enhance their professional skills;
• social commitment;
• the protection of health, safety and the environment;

and, more generally, the refusal of any conduct which, although aimed at achieving a result consistent with the interest of the company, presents aspects that are not compatible with an organisational and management model characterised by absolute compliance with the law and rules behavioural and procedural rules that apply within Petroltecnica.

Consequently, Petroltecnica undertakes to monitor compliance with the Code of Ethics, providing adequate information, prevention and control tools and intervening, where necessary, with adequate corrective actions.

2. RECIPIENTS, SCOPE OF APPLICATION AND UPDATING

The principles and provisions of this Code of Ethics are binding for all the following recipients:

• subjects who are in top positions within the company organisation (directors, managers);

• subjects who, within the company organisation, hold a subordinate position concerning the former (employees);
• external collaborators who, directly or indirectly, carry out services related to the company activity (consultants, external professionals);
• commercial or operational partners of the company who have a role in projects and operations.

All recipients undertake to pursue their objectives with loyalty, seriousness, honesty, competence and transparency, in full compliance with the laws and regulations in force.

It is the right/duty of everyone to contact their superiors or the SB in case of need for clarification on the methods of application of the rules of the Code of Ethics, as well as promptly report to the SB any information concerning possible violations of the Code itself, collaborating with the structures appointed to verify them.

Any violations committed by one’s own hierarchical manager shall be reported in writing to the Supervisory Body or a manager belonging to their organisational structure and shall be dealt with guaranteeing the confidentiality of the whistleblower. Control over the application of the Code of Ethics is delegated to General Management.

Where violations are detected, these shall be reported to the Board of Directors and the Supervisory Body so that the corporate bodies appointed can adopt any sanctioning measures against personnel who have violated the rules.

To this end, Petroltecnica undertakes to:

• encourage the maximum dissemination of the Code of Ethics, providing for its in-depth analysis and updating, also furnishing every employee with the management policies and guidelines defined for each area of activity;
• ensure a differentiated training programme and continuous awareness of issues relating to the code of ethics;
• carry out all the necessary checks on any information concerning possible violations, applying, in case of ascertainment of the same, adequate sanctions;

carry out all the necessary checks on any information concerning possible violations, applying, in case of ascertainment of the same, adequate sanctions;

3. RESPECT AND ENHANCEMENT OF HUMAN RESOURCES

3.1 Basic principles

Human resources are an indispensable element for the existence, development and success of every company: therefore, Petroltecnica pays particular attention to the enhancement, protection and development of all its employees’ skills and competences, so that they can express their maximum level of potential and professionalism.

The company offers all its employees equal job opportunities, according to their respective professional characteristics and performance capabilities, without any discrimination.

For this purpose, in compliance with all laws, regulations and company policies in force and through the competent functions, it undertakes to:

• select, hire, pay, train and evaluate employees based on merit, competence and professionalism criteria, without any political, trade union, religious, racial, language or gender discrimination;
• ensure a work environment where relations between colleagues are based on loyalty, correctness, collaboration, mutual respect and trust;
• offer adequate working conditions from the point of view of safety and health, as well as respectful of the moral personality of all, in such a way as to favour interpersonal relationships free from prejudice;
• intervene in the event of attitudes that do not comply with the principles set out above;
• combat, in particular, any form of intimidation, hostility, isolation, undue interference or influence, harassment

3.2 Development of professionalism

In the evolution of the employment relationship, the company favours the development of each resource’s potential and professional growth by providing specific training and refresher programmes concerning the professional profiles and potential of each.

Staff are required to solicit the acquisition of new skills and knowledge, work methods, information to their superiors or managers, while managers are required to pay the utmost attention to the enhancement of the potential and predisposition of staff.

4. INTERNAL RELATIONS

4.1 Rules of conduct for staff

The behaviour of employees in pursuing the objectives and concluding each operation must be inspired by the principles of honesty, transparency, loyalty, integrity and correctness, in compliance with company policies, as well as with the laws and regulations in force. The conviction of acting to the advantage of the company cannot, in any way, justify the conduct of conduct in contrast with the principles dictated by this Code of Ethics, the generalised observance of which is of fundamental importance for the proper functioning and prestige of Petroltecnica S.p.A. This commitment shall also apply to anyone who works in the name and on behalf of Petroltecnica S.p.A.

Any situation or activity that could lead to conflicts of interest or that could interfere with the ability to make impartial decisions shall be avoided.

In any case, where conflicts of interest arise that could interfere with the ability to make impartial decisions, the stakeholders shall refrain from making any decision and must promptly report the case; related decisions shall be left to the discretion of the higher level of responsibility.

The information acquired by employees and/or consultants in the performance of the assigned duties shall remain strictly confidential and shall not be disclosed within and outside the company except in compliance with current legislation and company procedures.

Company employees and/or consultants shall use company assets exclusively for the performance of their work activities.

It is forbidden to accept, for oneself or others, preferential treatment recommendations, gifts or other benefits from the subjects with whom one enters into a relationship, avoiding receiving benefits that may be such as to compromise the impartiality of judgment.

The decisions taken by each employee and by the Management shall be based on the principles of sound and prudent management in the awareness that they contribute to the achievement of positive company results.

4.2 Privacy compliance 

Petroltecnica, which has always respected the right to privacy and the correct processing of personal data, applies the Code for the protection of personal data (Legislative Decree 196/2003) to ensure perfect compliance with the legislation in force.

The company’s commitment to the application of regulatory devices is summarised in the following bullet points:

• the data controller is Petroltecnica S.p.A.;
• the data controller appoints data managers, in the number of one or more, and persons in charge of processing: they will be the only ones authorised to carry out operations on the archived data, differentiating their respective competences under the direction and supervision of the data controller;
• each interested party is informed in advance, where required, orally or in writing about the processing methods set out in Article 13 of the Code;
• the minimum indispensable measures prescribed in Chapter II of the Code are adopted, as well as the appropriate, specific and periodically updated ones established in the Technical Regulations on minimum security measures (“Annex B” to the Code);
• conforms the installation procedure of audiovisual equipment, if necessary and functional to organizational and production needs or to a reduction of risks to guarantee greater safety in the workplace, to the provisions of Articles 4 and 38 of the Workers’ Statute (Law no. 300/1970);
• enforces the ban on investigations into opinions and facts that are not relevant for assessing the professional aptitude of its employees, under Articles 8 and 38 of the aforementioned Articles of Association;
• lastly, it provides for the training of the owners and persons in charge of current legislation, the methods of treatment, the right of access of the interested parties and the penalties provided for in the event of non-fulfilment of legal obligations or unlawful conduct in the data processing.

5. EXTERNAL RELATIONS

5.1 Relations with public administration

In the context of relations with the PA, particular care must be taken not to carry out acts in violation of the provisions of the law and this Code of Ethics.

In particular, it is expressly forbidden to:

• mislead by using tricks or deception to achieve an unjust profit to the detriment of the State, another public body or European Union. In particular, it is recommended that the law and correct commercial practice be respected regarding tenders, negotiations, concessions, licenses, and requests for financing, contributions, subsidies and disbursements from the State or other entity belonging to the Public Administration;

• Using or submitting false declarations or documents or omitting information required to obtain grants, loans, soft loans or other disbursements of the same type granted or disbursed by the State, by other Public Bodies or by the European Union;
• Allocating a loan obtained from the state, or from another public body or from the European Union for a different use to favour other initiatives;
• Altering the functioning of an IT or telematic system by manipulating the data or programmes contained therein to obtain an unfair profit and damaging the public administration;
• Accepting money for undue services: whoever receives such requests must suspend all relations with them and inform the SB in writing;
• Offering or promising, even indirectly, money or other benefits to omit or delay acts or perform acts contrary to one’s own

5.2 Customer and supplier relationships

Relations with customers and suppliers shall be conducted with correctness, transparency and impartiality by qualified personnel.

The selection of suppliers shall take place exclusively based on objective parameters such as convenience, quality and efficiency, to protect Petroltecnica’s assets.

5.3 Gifts, benefits and promises of favours

During the business negotiation or commercial relationship both with the PA and with customers and suppliers, general criteria of correctness, transparency and integrity shall be applied.

In particular, these shall not be:

• examined or proposed or promised employment and/or commercial opportunities that may benefit PA employees or customers/suppliers, directors and managers of customers/suppliers in a personal capacity;
• offers in any way gifts, donations, even indirect benefits, goods, services and services or favours that are not due or that go beyond ordinary courtesy relationships;
• solicited or obtained confidential information that could compromise the integrity or reputation of both parties as well as bring significant direct or indirect benefits to themselves or Petroltecnica;

• took actions to improperly influence decisions.
• Furthermore, managers, employees or collaborators in any capacity of the company shall not accept any good or service, gift, benefit, performance or bestowal that goes beyond the ordinary relations of courtesy, from external or internal subjects in any case and in particular concerning the initiation of actions or behaviours aimed at favouring such.

Employees who receive gifts or preferential treatments from agents of the PA, customers or suppliers that go beyond ordinary courtesy relations shall immediately notify their superior or the Supervisory Body.

6. USE AND PROTECTION OF COMPANY ASSETS

All employees and collaborators shall remember that the Company’s tangible and intangible assets made available to them are to be used:

• with the utmost care and in a proper way, also to prevent any damage or injury;
• avoiding (where possible) any waste, tampering or uses that could compromise their efficiency or accelerate their normal wear and tear;
• solely for purposes connected and/or instrumental to the performance of their work;
• absolutely avoiding – except as provided for by specific regulations – the use or transfer of the same assets by third parties or to third parties.

All employees and collaborators are responsible for the use and custody of the assets granted to them by Petroltecnica.

Even the IT equipment and applications shall be used in compliance with the above and in particular:

• carefully abiding by corporate security and confidentiality policies;
• absolutely avoiding the acquisition, use or transmission, especially if massive, of information and content not relevant to the business;
• not altering the hardware and software configurations provided

• In compliance with the laws in force, the Company carries out checks and implements measures to prevent behaviour that are not in line with the aforementioned.

All employees shall also act to reduce the risk of theft, damage or other external threats to the resources assigned or present in the Company, by promptly informing the relevant Departments in case of anomalous situations.

7. CONFLICT OF INTEREST

Between Petroltecnica and its directors and employees at any level, there is a relationship of full trust, where it is the primary duty of the administrator and the employee to use the assets of the company and their working skills for the realisation of the corporate interest, in compliance with the principles established in the Code of Ethics that represents the values which Petroltecnica inspires.

In this context, the Company’s directors, employees and collaborators of various types should avoid any situation, and refrain from any activity, which could cause conflict between a personal interest and the interests of the Company, or which could interfere with the ability to make impartial and objective decisions on the Company’s behalf.

Situations involving a conflict of interest are not only against the law and the principles set out in the Code of Ethics, but are also detrimental to the image and integrity of the company.

All employees, collaborators and consultants, as laid out above, shall therefore reject any possibility of exploiting their role within the Company to favour personal and/or family interests.

Any situations of conflict, even if potential, shall be promptly and in detail communicated to the Company – in the person of their hierarchical superior and, if necessary, to the SB, under Legislative Decree 231/01 -. Any subject in a potential conflict shall refrain from carrying out or participating in acts that could harm the Company or third parties or even compromise its image.

8. USE AND DISCLOSURE OF INFORMATION

Petroltecnica considers the dissemination of correct, complete and truthful information on all company facts – and the maintenance of due confidentiality on the same, when necessary

• as a prerequisite for creating and maintaining a relationship of transparency and trust with its stakeholders and related interests.

Consequently, in the management of information, employees shall:

• keep scrupulously and with the utmost confidentiality all corporate information of any type learned in the exercise of their functions;
• request consent to the processing of personal data/li>

In relation to information in general, employees shall:

• avoid improper or instrumental use of those reserved in their possession, nor use them for their own benefit and/or that of family members, acquaintances and third parties in general;
• protect them from access by unauthorised third parties, prevent their dissemination unless specifically authorised by the Manager;
• not to seek, or try to obtain from others, those not related to their sphere of competence or functions;
• classify and organise them in such a way that it is possible, for authorised parties, to access them easily and drawing a picture of them

To Employees not expressly authorised, in the forms and terms set out in Legislative Decree no. 196/2003, concerning the protection of persons and personal data, it is forbidden to know, register, process and disclose the personal data of other employees or third parties.

9. TRANSPARENCY IN ACCOUNTING

9.1 Accuracy and transparency of official documentation

All official documents aimed at illustrating the management situation of the company shall be drawn up with the utmost care to guarantee their accuracy and truthfulness. They shall also be drawn up following applicable laws and regulations.

In drafting the aforementioned documents, Petroltecnica staff shall pay due attention and maintain those behaviours based on principles of correctness, honesty and integrity that shall inform the performance of the professional activities within their competence.

In any case, it will not be justified, nor justifiable, the keeping or drafting of documentation deliberately false or artificial to significantly alter the truthful representation of Petroltecnica’s situation.

9.2 Registration and documentation of transactions

Every operation, action and transaction of the company shall be adequately recorded and documented to allow verification of the decision-making, authorisation and execution processes.

Every act or operation carried out by the staff shall be supported by adequate, clear and complete documentation to be kept in the records, to allow the control over the reasons, the characteristics of the operation and the identification of the subjects who operated, which granted the authorisations and carried out the verifications at any time.

9.3 Accounting transparency

All company functions are required to provide the utmost cooperation to ensure correct and timely accounting records. Accounting records based on economic and equity valuations shall comply with the criteria of reasonableness and prudence.

Adequate documentation shall be kept on file for each accounting entry. This documentation shall make it possible to identify the reason for the operation that generated the recognition and the related authorisation.

Supporting documentation shall be archived and easily accessible.

Anyone who becomes aware of possible omissions, falsifications or irregularities in the keeping of the accounts must immediately notify their superior or the SB.

10. HEALTH PROTECTION AND SAFETY

Petroltecnica, aware of the importance of guaranteeing the best conditions of health and safety in the workplace, undertakes to promote and disseminate responsible behaviour among its employees, implementing the necessary preventive actions, to preserve health, safety and security of all personnel as well as third parties who frequent their premises.

The culture of health and safety is spread systematically, through training and communication moments, and is achieved through a continuous updating of methodologies and systems, in the light of the best technologies available, carrying out an analytical assessment of the risks, of the criticalities of the processes and resources to protect.

Corporate officers who hold sensitive roles for health and safety purposes undertake to comply with the rules and obligations deriving from this in terms of prevention and protection, setting themselves, however, objectives of excellence that go beyond mere fulfilment, in full awareness of the value represented by safeguarding the health, safety and well-being of the staff.

11. ENVIRONMENTAL PROTECTION AND ENERGY POLICY

Petroltecnica applies the highest standards in environmental protection and complies with all requirements of environmental, national and local laws. In cases not provided for by specific environmental protection laws, the company indicates and applies rigorous behavioural protocols.

Energy-saving and the protection of natural resources are fundamental values and primary objectives of the Company to minimise the effects for the environment of its work and to achieve better integration with the communities where Petroltecnica operates.

Every employee involved in processes and activities that can have environmental repercussions is called to carry out their work with the utmost conscientiousness, checking and possibly reporting the accidental discharges and emissions of harmful materials, and treating hazardous waste with due care. Each member becomes primarily responsible for the application of environmental protection regulations.

Also on this fundamental point of its business, Petroltecnica adopts a series of key principles of the company policy, which provide for:

• total relevance and compliance with current environmental regulations, in particular Legislative Decree 152/2006, and its subsequent amendments and additions;
• acts in such a way as not to cause damage to the environment, planning its activities in search of a balance between initiatives, economic/production needs, environmental needs and the rights of future generations;
• invests in the innovation of its service and energy-saving techniques to guarantee a perfect match between efficiency in the field and the reduction of impact risks

Following these principles, Petroltecnica has obtained the certification of efficiency and effectiveness of its procedures in the field of environmental and energy protection, according to the International Environmental Management System UNI EN ISO 14001: 2004 (Environmental Management System).

11.1 Notification of violations (whistleblowing)

The task of all employees is to protect the environment. To this end, in addition to the procedures, obligations and provisions prescribed by law, the company urges its staff to immediately report any violation of environmental regulations or actions that tend to commit or conceal these, to their direct superior or the competent corporate body.

12. REPORTING OBLIGATIONS

If any recipient becomes aware of situations, even if only potentially illegal or contrary to the principles expressed in this Code of Ethics, which directly or indirectly benefit Petroltecnica or are committed in its interest, they shall immediately inform the SB, or its delegated, giving notice in writing, also electronically, with exemption from the obligation of compliance with the pre-established hierarchical order. Failure to comply with the duty to inform can be sanctioned.

The reports received are rapidly examined and processed by the SB following the provisions of the Model. Any sanctions are assumed and imposed based on the disciplinary system envisaged by the Model.

Relations between employees, at all levels, shall be based on principles and conduct of correctness, collaboration, loyalty and reciprocal respect. Therefore, the abuse of the duty of information governed by this chapter for retaliation or merely emulative is punishable.

13. SANCTION SYSTEM

Even within the introduction to this Code of Ethics, the strong call for a precise and punctual compliance with all the law by each employee in carrying out their work is evident. Failure to comply can only lead to the application of the sanctioning procedures provided for by the rules themselves or by ad hoc laws against the employee. Respect for the Code of Ethics, on the other hand, shall arise more than from an obligation imposed by Petroltecnica towards its employees, from their sharing of the fundamental values set out in it. This does not, however, exclude the right/duty of Petroltecnica to monitor compliance with the Code of Ethics, implementing all the actions, prevention and control, deemed necessary or appropriate for the aforementioned purpose.

The violation of the rules of the Code of Ethics compromises the fiduciary relationship established and constitutes a breach of the primary obligations of the employment relationship or a disciplinary offence, with all legal consequences, also about the preservation of the employment or collaboration relationship.

Therefore, in the event of ascertained violations, Petroltecnica S.p.A. intervenes by applying the measures provided for by the sanctioning system under Article 7 of Law no. 300 dated 20 May 1970, Article 2119 and 2106 of the Civil Code, under Legislative Decree no. 231 dated 8 June 2001, and to the collective and regulatory legislation applied to the type of employment relationship.

Any violation by consultants, collaborators, suppliers, self-employed workers and in general external collaborators and partners is a source of contractual liability and as such is sanctioned based on the general principles of law and the rules governing the related relationships contractual.

These measures, proportionate to the seriousness of the infringements committed, are applied in compliance with the procedure prepared for this purpose, provided that the infringements from which they arise do not constitute violations, in addition to the rules of the Code of Ethics, also of contractual and legal regulations.

In this case, the penalties provided for by the relevant legislation are applied.

As regards violations by individuals in top positions, Directors or Legal Representatives, the SB will formalise the communication to the Shareholders’ Meeting for the appropriate resolutions.