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Code of Conduct

organization and management model

Organization and management model ex Legislative Decree 231/01

Il Decreto Legislativo n. Legislative Decree no. 231 of 2001 introduced the administrative liability of companies for certain crimes committed by employees in the interest of and to the advantage of the companies themselves, with consequent fines and disqualification of the companies. Moreover, the Decree provides for the exemption of the companies from this liability if they demonstrate that they have:

a) effectively and efficiently adopted an internal control model suitable for preventing the crimes provided for;

b) surveillance of the functioning and observation of the models and their updating are entrusted to a body (Supervisory Body) provided with autonomous powers of control and initiative.

Netgroups’ Board of Directors has adopted the model and nominated a Supervisory Body as provided for in D.Lgs. no. 231/2001, a multimember body composed of two external members, an expert in company law, and an IT expert. n. The Supervisory Body, provided with the necessary requirements of autonomy, independence, and competence, is responsible for updating Model 231 concerning the current regulatory panorama in force and for the internal organizational structure, supervising the updating of Model 231 and its concrete activation.

The Supervisory Body, provided with the necessary requirements of autonomy, independence, and competence, is responsible for updating Model 231 concerning the current regulatory panorama in force and for the internal organizational structure, supervising the updating of Model 231 and its concrete activation.

The “Code of Conduct according to Legislative Decree 231/2001” contains the rules aimed at guaranteeing the behavior of subjects addressed. They should always be inspired by the criteria of correctness, co-operation, loyalty, transparency, and reciprocal respect as well as avoiding criminal and illegal administration and management including all that is listed in Legislative Decree 231/01. 231/01.