CODE OF ETHICS AND ORGANISATIONAL MODEL PURSUANT TO LEGISLATIVE DECREE 231/2001

Svicom conducts its business in accordance with the principles of integrity, transparency, accountability, fairness and respect for people, fostering a corporate culture focused on creating sustainable value for clients, employees, partners, communities and stakeholders.

The Code of Ethics serves as the fundamental reference framework for the conduct and decision-making of all individuals working for the Group, defining the values, principles and standards of behaviour that guide the Company’s activities.

In line with the principles of the Code of Ethics, Svicom has adopted an Organisational, Management and Control Model pursuant to Italian Legislative Decree No. 231/2001, designed to prevent the commission of offences that may give rise to the administrative liability of the Company.

The 231 Organisational Model, together with the Group’s system of procedures, internal controls and governance mechanisms, contributes to ensuring a management approach based on legality, transparency, efficiency and accountability, reinforcing Svicom’s commitment to the highest ethical and professional standards.