CODE
OF ETHICS

SOC. LIGHTHOUSE S.T.A. SRL (hereinafter the “Company”) is an Italian company with its registered office in Milan, Largo Francesco Richini 6, operating primarily in the activities of law firms, with particular experience and operations in the field of credit management and protection and related enforcement proceedings.

The Company believes in the value of work and considers legality, fairness and transparency of action to be essential prerequisites for achieving its economic, productive and social objectives. The Company has always paid close attention to ethical values and, in particular, it:

• does not accept compromises in terms of the quality and ethics of its work;
• balances the three financial, social and environmental dimensions;
• requires its employees to be open, honest, ambitious and reliable with all stakeholders;
• offers the people who work for the Company the opportunity to realise their potential.

In this context, the Company — also in order to comply with the requirements of Legislative Decree No. 231/2001 (hereinafter the ‘Decree’) — has adopted its own Code of Ethics (hereinafter the “Code of Ethics” or simply the “Code”) which, in accordance with the CONFINDUSTRIA Guidelines, is one of the fundamental protocols for building an adequate Organisation, Management and Control Model (hereinafter also the ‘Model’) pursuant to the Decree.

The Code of Ethics is an integral part of the Model adopted by the Company and sets out not only the fundamental and more general values, but also the rules of conduct that guide the Company’s business.

The Code of Ethics is the reference point for guaranteeing the highest standard of ethical behaviour in the conduct of the Company’s business by all those who act on behalf of and in the interest of the Company.

The Company has adopted this Code of Ethics, which describes the objectives of corporate action and gathers a number of guiding principles, providing employees with clear guidance on the direction to follow.

In particular, LIGHTHOUSE STA Srl complies with the principles set out in the CONFINDUSTRIA Guidelines.

This Code is binding on all the parties indicated below (collectively referred to hereinafter as ‘Addressees’ or, individually, as ‘Addressee’):

• the members of the Corporate Bodies (directors / sole director and statutory auditors);
• the Company’s employees, including those holding managerial positions (hereinafter jointly referred to as ‘Personnel’);
• all those who, although external to the Company, operate directly or indirectly on behalf of Lighthouse STA Srl (e.g. agents, attorneys, collaborators, consultants, suppliers and partners, hereinafter jointly referred to as ‘Third-Party Addressees’).

All Addressees are required to observe and, to the extent of their responsibilities, to ensure observance of the principles contained in the Code of Ethics.

The Company undertakes to ensure the timely internal and external dissemination of the Code of Ethics.

With particular reference to the Corporate Bodies and the Personnel, it guarantees:

• the distribution of the Code of Ethics to all members of the Corporate Bodies and to all Personnel;
• its inclusion in the company intranet, in order to allow consultation as well as the assessment of facts in cases of alleged violations;
• assistance in interpreting and clarifying the provisions contained in the Code;
• the design of systems to verify the actual observance of the Code of Ethics.

The Supervisory Body (hereinafter the ‘OdV’ or simply the ‘Body’) promotes and monitors training initiatives on the principles of the Code of Ethics, structured and differentiated according to the role held and the responsibilities assigned to the relevant resources. Training will be more intensive and characterised by a higher degree of detail for those operating in the so-called “at-risk” areas under the Model.

With particular reference to Third-Party Addressees, the Company requires them to comply with the Code of Ethics and therefore arranges to:

• make the Code of Ethics available (the Code of Ethics will in any case be available on the official company website);
• prepare and have signed contractual clauses intended to formalise the commitment to comply with the provisions of the Decree, the Model and the Code of Ethics, and to govern the contractual penalties that will be applied following any breach of such commitment. The Company will see to the definition and continuous improvement of such clauses.

Monitoring the implementation of and compliance with the Model and the Code of Ethics is entrusted to the OdV. In addition to the provisions set out in the General Section of the Model, some of the Body’s tasks are indicated below by way of example:

• monitoring and verifying compliance with the Model and the Code of Ethics by the company’s contact persons;
• reporting any violations identified to the competent corporate bodies;
• promoting updates to the Code of Ethics by formulating its own proposals;
• promoting and monitoring the Company’s communication and training activities on the Model and on the Code of Ethics, of which it is an integral part.

Observance of the rules of the Code must be regarded as an integral part of the contractual obligations of the Company’s employees within the meaning and for the purposes of Articles 2104 et seq. of the Italian Civil Code.
Violation of the rules of this Code, regarded as particularly serious, also damages the relationship of trust established with the Company and may lead to disciplinary action and claims for damages, without prejudice — for employees — to compliance with the procedures set out in Article 7 of the Workers’ Statute, the applicable collective labour agreements and any company regulations.
Violation of the rules of the Code of Ethics entails the application of the penalties provided for in the Disciplinary System, to which reference is made and which forms an integral part of the Model adopted by the Company.

Should anyone become aware of a violation — even merely a potential one — of the rules contained in this Code and of the provisions of the Model, they are obliged to report it to the OdV, including anonymously.
Reports may be made by email to the mailbox odvlighthousesta@gmail.com or in writing, by sending a specific communication, including anonymously, to the address: Supervisory Body, c/o Soc. LIGHTHOUSE STA SRL, registered office in Milan, Largo Francesco Richini 6.
The OdV takes steps to ensure that those who have made reports are not subject to retaliation, discrimination or, in any case, penalisation, ensuring appropriate confidentiality for such persons. In any event, a report made in good faith may in no case constitute grounds for retaliation or penalisation against the reporting person. Threats, harassment, discrimination of any kind, demotion, denial of benefits, suspension, termination of employment and any conduct that may be retaliatory or penalising towards the author of the report will not be tolerated.
Anyone who believes they are the subject of retaliation, or is aware of retaliatory conduct adopted against others, may contact the Company’s Supervisory Body

Lighthouse undertakes to comply with the laws, regulations and, more generally, the rules in force in Italy and, where applicable, in all countries with which it has connections. The Company also undertakes to comply with the rules and the ethical and professional principles laid down by the relevant trade associations. In no case is it permitted to pursue or realise the Company’s interest in violation of the law or of professional principles.

Each Addressee carries out their work and performs their duties with diligence, efficiency and fairness, making the best use of the tools and time available to them and assuming the responsibilities connected with the tasks within their remit.

Lighthouse STA condemns any form of discrimination based on sex, nationality, status, religion, personal and political opinions, age, health, political beliefs or sexual orientation, or economic conditions, and does not allow the use of any form of physical, verbal or even merely psychological violence aimed at obtaining conduct contrary to the rules in force, including the professional principles codified in this Code.

The Company works to continuously improve its economic results by setting high targets for growth and value creation in order to achieve competitive results, and maintains an open dialogue with all stakeholders, adhering to the highest international reporting standards. Lighthouse STA’s accounts are kept in accordance with the provisions of the Italian Civil Code and the International Accounting Standards (IAS). All actions and transactions of Lighthouse STA Srl must be properly recorded, and it must be possible to verify the decision-making, authorisation and execution process.
Every transaction must have adequate documentary support so that, at any time, it is possible to carry out checks attesting to the characteristics and reasons for the transaction and identifying the persons who authorised, executed, recorded and verified it. Accounting records must be kept accurately, completely and promptly, in compliance with company accounting procedures, in order to provide a faithful representation of the financial position and of management activities.
To this end, all employees involved in accounting records must ensure the utmost cooperation, the completeness and clarity of the information provided, and the accuracy of data and processing. It is expressly prohibited to prevent or hinder — by concealing documents or through other suitable artifices — the performance of the control activities assigned to the shareholders, to other corporate bodies and to the authorities.

All actions and transactions carried out, and all conduct adopted in the performance of duties or assignments, must be guided by lawfulness from both a formal and a substantive standpoint and by the protection of the Company, in accordance with the rules in force, internal procedures and fairness. Addressees must not use, for personal purposes, information, assets and equipment available to them in the performance of their duties or assignments. No Addressee may accept or make — for themselves or others — pressures, recommendations or referrals that may harm the Company or result in undue advantages for themselves, the Company or third parties; furthermore, each Addressee must reject and must not make promises of undue offers of money or other benefits.
Each Addressee of this Code is required to demonstrate professionalism, dedication, loyalty, a spirit of cooperation and mutual respect. No one in the Company may ever compromise to the detriment of quality and ethics.

In compliance with national and EU antitrust regulations, as well as the Guidelines and directives of the Competition and Market Authority, the Company does not engage in conduct nor enter into agreements that may negatively affect competition among the various operators in the relevant market or that may harm users and consumers in general, guiding its conduct by commercial fairness and preventing and condemning unfair practices of any kind and nature.
The Company also undertakes not to unduly damage the image of competing companies and their services or products.

Lighthouse STA srl protects personal data in compliance with the European and national legislation in force, in order to avoid breaches of the data subject’s personal data. Addressees in possession of information that is not in the public domain or that is otherwise confidential must in no case disclose such information to parties inside or outside the Company. Confidential information includes, by way of example and without limitation: information on trading transactions with clients, the content of transactions and information acquired to contact debtors, techniques relating to services and procedures; purchasing programmes; cost, pricing, marketing or service strategies; revenue reports and other non-public financial reports; information relating to sales, mergers and acquisitions.
Confidential information relating to research activities may be exchanged only after appropriate measures have been put in place to protect the Company from an industrial and intellectual property standpoint and the necessary measures to protect the personal data of the parties involved have been arranged. Confidential information disclosed by the Company must be regarded as a professional secret and as material protected by the Company’s rights; failure to obtain the Company’s authorisation to disclose, or the unauthorised use of, any information obtained during the contractual relationship constitutes unfair competition against the Company and gives rise to the relevant legal consequences. The acquisition, processing and storage of information and personal data of employees and other parties whose data the Company holds take place in compliance with specific procedures designed to ensure that unauthorised persons and/or entities cannot gain access to it. Such procedures comply with the regulations in force.

The management of human resources is based on respect for the personality and professionalism of each individual within the general framework of current legislation. Access to roles and/or assignments is defined on the basis of the skills and abilities of individuals, in line with the Company’s specific needs and without any discrimination. Consistent with the criteria of general work efficiency, the Company promotes forms of organisational flexibility that facilitate the management of maternity and, more generally, childcare.
Within personnel management and development processes, the decisions taken from time to time are based on the actual correspondence between the profiles held by employees and the planned or reasonably expected objectives, as well as on related considerations. The Company makes use of and enhances all the professional skills present in its structure, so as to foster the development and growth of personnel through the most appropriate means. Any form of abuse of positions of authority or coordination is expressly prohibited. Abuse means any conduct consisting in requesting or inducing the provision of services, personal favours or other benefits detrimental to the dignity, professionalism or autonomy of others. The high professionalism of its collaborators and their dedication to the Company are essential and decisive factors for the pursuit of the Company’s objectives. For this reason, Lighthouse STA protects professional growth and development and condemns any form of favouritism, nepotism and patronage.

Lighthouse pursues the objective of the utmost integrity and fairness in its relations with public institutions and, more generally, with the Public Administration, in order to guarantee maximum transparency in institutional relations.
In relations with public officials or with representatives of the Public Administration, local authorities, public bodies or those performing a public service, conduct guided by the utmost fairness and honesty must be maintained.
The Company rejects any form of corruption or undue influence towards representatives of the Public Administration. It is therefore prohibited to make any kind of payment or to provide any benefit in dealings with Institutions or Public Officials, including their family members and persons closely connected to them.

It is therefore generally prohibited to:

• offer gifts, money or any benefit in order to obtain unlawful advantages;
• promise, offer or grant, directly or indirectly, payments or any benefit (gifts, presents, favours, etc.) to public officials or persons in charge of a public service, their family members and, in any case, persons closely and notoriously connected to them, in order to influence or reward an act of their office or the omission of an act of their office or an act due.

Acts of courtesy, such as gifts, are permitted only when of modest value (not exceeding EUR 100.00) and, in any case, such as not to compromise the integrity or reputation of either party and such that they cannot be interpreted by an impartial observer as aimed at improperly acquiring advantages. Relations with institutional counterparts are maintained exclusively through the persons designated for this purpose. Where a consultant or a “third party” is used in dealings with the Public Administration, that person will be required to comply with the directives applicable to Addressees; furthermore, the Company must not be represented, in its dealings with the Public Administration, by a consultant or a “third party” where conflicts of interest exist, including potential ones.

Lighthouse STA works to continuously improve its environmental compatibility by setting high objectives and integrating environmental and bioethical requirements into its daily activities. It maintains an open dialogue with its stakeholders and promotes actions and decision-making processes in a sustainable manner. Lighthouse STA is aligned with the legislation in force at national and international level. All the Company’s activities must be carried out in compliance with the provisions of environmental legislation.

The Company works to continuously improve its results in the social field by setting high objectives and integrating social needs, respect for human rights, and health and safety into its daily activities.

It maintains an open dialogue with all its stakeholders and respects the United Nations Universal Declaration of Human Rights.

The Company refrains from financing political parties, movements, committees and political and trade-union organisations, or their representatives or candidates. Nor does it finance associations or sponsor events or conferences whose purpose is political propaganda. The Company grants contributions and donations in favour of parties with social, moral, scientific and cultural purposes.

Lighthouse rejects any form of terrorism and undertakes to adopt — in the conduct of its business — all necessary measures to prevent the risk of the Company being involved in acts of terrorism, in order to contribute to the affirmation of peace among peoples and of democracy.
To this end, the Company sets itself the objective of not establishing any relationship — whether of an employment, commercial or sponsorship nature — with parties involved in acts of terrorism, whether natural or legal persons, and further undertakes not to finance or facilitate any of their activities.
Lighthouse STA likewise rejects any form of criminal organisation, whether national or transnational and, to this end, undertakes not to establish any employment, collaboration or commercial relationship with parties — whether natural or legal persons — directly or indirectly involved in criminal organisations or, in any case, linked by ties of kinship and/or affinity to members of known criminal organisations, just as it does not finance or otherwise facilitate any activity attributable to such organisations.

The Company recognises the need to protect individual freedom in all its forms and rejects any manifestation of violence, especially where aimed at restricting personal freedom. The Company undertakes to promote, within its business and among its employees, collaborators, suppliers and partners, the sharing of these same principles.

Lighthouse STA sets itself, with the utmost commitment, the goal of guaranteeing health and safety in the workplace. To this end, the Company adopts the measures suitable to avoid the risks connected with the conduct of its business and, where this is not possible, undertakes to carry out an adequate assessment of existing risks, setting itself the objective of combating them at source and ensuring their removal or, where this is not possible, their management. The Company adopts all suitable measures to guarantee the protection of workers’ safety and health, including occupational risk prevention, information and training activities, and the provision of the necessary organisation and resources.

Lighthouse STA operates in full compliance with the legislation in force on the protection of trademarks, patents and other distinctive signs, as well as copyright. The Company does not permit the use of intellectual works lacking the S.I.A.E. mark or otherwise bearing an altered or counterfeit mark. The Company also prohibits the reproduction of software and database contents, as well as the appropriation and dissemination — in any form — of protected intellectual works, including by revealing their content before it is made public.

The Company does not permit the use — on any basis and for any purpose — of products bearing counterfeit trademarks or signs, nor their manufacture or marketing or, in any case, any activity concerning products already patented by third parties and over which it holds no rights.

In recognising the value of full cooperation with the Judicial and administrative Authorities, Lighthouse STA pursues the objective of acting with the utmost integrity and fairness in its relations with the competent Authorities. To this end, the Company prohibits any conduct aimed at or suitable for interfering with investigations or inquiries conducted by the competent Authorities and, in particular, any conduct directed at hindering the search for the truth, including by inducing persons summoned by the Judicial Authority not to make statements or to make false statements. The Company undertakes to adopt all suitable measures to provide the cooperation requested by the Authorities, in compliance with the legislation in force.

The Company sets itself the objective of using IT and/or telematic services correctly, in compliance with the legislation in force and in such a way as to guarantee the integrity and authenticity of the data processed, protecting the interests of the Company and of third parties, with particular reference to the public Authorities and Institutions. That being said, it undertakes to adopt all suitable measures to ensure that access to telematic and IT data takes place in full compliance with the regulations in force and with the protection of the personal data of any parties involved, and in such a way as to ensure the confidentiality of information and that its processing is carried out by expressly authorised persons, so as to prevent undue intrusions.

In particular, the Company prohibits:

• gaining unlawful access to IT or telematic systems protected by security measures;
• destroying, damaging, deleting or altering information, data or computer programs belonging to others, to the State or to other public bodies;
• producing forged electronic documents, whether private or public, having evidentiary value;
• installing equipment intended to intercept, prevent or interrupt communications relating to an IT or telematic system, or between several systems;
• unlawfully obtaining, reproducing, disseminating or delivering codes, passwords or other means suitable for accessing an IT or telematic system protected by security measures.

Lighthouse STA, prohibiting any form of corruption, considers it a fundamental and essential value that relations with private parties (suppliers, competitors, clients, consultants, business partners, etc.) be based on the utmost loyalty, integrity, fairness and good faith.

One of the central aspects that ethically qualify the Company’s conduct is compliance with the principles of conduct designed to guarantee the integrity of the share capital, the protection of creditors and of third parties who establish relations with the Company, and, in general, the transparency and fairness of the Company’s activity from an economic and financial standpoint.

The Company therefore intends to ensure the dissemination and observance of rules of conduct intended to safeguard the aforementioned values, also in order to prevent the commission of corporate offences contemplated by Legislative Decree 231/2001.

Addressees must not be implicated or involved in transactions that may entail the handling of goods of unlawful origin or the laundering of criminal or unlawful proceeds. The Company pursues the objective of the utmost transparency in commercial transactions and puts in place all suitable instruments to combat any phenomenon of handling stolen goods, money laundering, the reuse in economic and financial activities of unlawful proceeds, and self-laundering.

The members of the corporate bodies, in addition to complying with the provisions of the law and of the articles of association and with the professional code of conduct, are required to observe the provisions of the Model and of the Code of Ethics that forms part of it. In particular, the corporate bodies must:

• behave loyally and responsibly towards the Company;
• follow, in the exercise of their functions, criteria of autonomy, independence and fairness with private parties, public institutions, political forces, and any other national and international operator;
• refrain from carrying out acts in situations of conflict of interest in the course of their activities;
• not hinder the control activities of the shareholders, of the other corporate bodies and of the Supervisory Body;
• make confidential use of the information they become aware of for official reasons, avoiding using their position to obtain advantages, whether directly or indirectly, safeguarding price-sensitive information and information covered by trade secrecy;
• comply, to the extent of their responsibilities, with the rules of conduct laid down for Personnel in the following paragraph III.3.

As indicated, the Code of Ethics also applies to “Third-Party Addressees”, i.e. those parties external to the Company who operate, directly or indirectly, on the Company’s behalf (e.g., purely by way of example, agents, collaborators on any basis, consultants, suppliers, business partners). Third-Party Addressees are obliged, to the extent of their responsibilities and as applicable to them, to comply with the provisions of the Model and of the Code of Ethics and, in particular, with the fundamental ethical values indicated above and with the rules of conduct laid down for Personnel, set out in the following paragraph. To this end, specific clauses are included in engagement letters and contracts in order to govern any failure to comply with the Model or the Code of Ethics.

In addition to the ethical principles of this Code, the legislation in force, and internal national and international policies and procedures, Personnel must also comply with the rules of conduct indicated below.

All relations with parties qualifying as Public Officials or Persons in charge of a Public Service must be conducted in absolute compliance with all applicable laws and regulations, with particular reference to anti-corruption rules. It is prohibited to accept, offer or promise, even indirectly, money, gifts, goods, services, performances or any benefit — including in terms of employment opportunities — in connection with relations with Public Officials or Persons in charge of a Public Service, in order to influence their decisions, with a view to more favourable treatment or undue performances or for any other purpose, including the performance of acts of their office. Any requests for or offers of money, gifts or presents, or favours of any kind, made or received by Personnel must be promptly brought to the attention of their line manager, the Supervisory Body and the legal function.

Personnel must avoid carrying out or facilitating transactions in conflict of interest — actual or potential — with the Company, as well as any activity that may interfere with the ability to make decisions impartially in the Company’s interest and in compliance with the rules of this Code. Addressees must inform their superiors or contact persons without delay, having regard to the circumstances, of situations or activities in which they might hold interests in conflict with those of the Company (or where close relatives hold such interests), and in any other case where significant reasons of expediency arise.

Addressees must comply with the decisions taken in this regard by the Company. In particular, each Addressee is required to promptly inform their superior of any relationship of kinship, even if not close, that exists between them and:

• other employees of the company;
• suppliers;
• clients;
• employees of the Public Administration;
• other categories not listed above but which may have, directly or indirectly, a relationship of any kind with the Company.

Pending the company’s decisions on the matter, abstention from carrying out any transaction is required.

Personnel must conduct relations with clients, bodies and institutions, etc. — and with suppliers — with the utmost fairness and transparency, in compliance with the laws and rules in force, the Model and the Code of Ethics, as well as internal, local and group procedures. Specific procedures are adopted that guarantee equal treatment and impartiality of suppliers, as well as the use of objective and transparent criteria for selection, based on objective assessments relating to competitiveness, quality and the economic conditions offered.

The Company may provide its support to independent, educational or scientific conferences, or to companies that promote scientific knowledge in the field of credit protection, organised by international, national, local or specialist associations. As regards everything relating to the assessment of the quality of the event, the choice of the period, the location and the venue, the provision of meals, financial contributions for costs (e.g. reimbursement of travel and accommodation expenses, etc.) and financial support for the organisers, the criteria and limits established by internal procedures must be strictly adhered to. The Company may purchase advertising and rent space for exhibition stands for its services during conferences.

In the course of its business activities, the Company may make use of the collaboration of professionals to whom — in compliance with the legislation in force — it may entrust consultancy assignments. The particular nature of the activity carried out requires the Company to identify the professional figures most suited to the assignment of such activities. The choice of consultants must be based on their qualifications and experience. Where an employee or director of the Company considers it appropriate to begin a collaboration with a professional, they must ensure that the rules established by internal procedures are complied with as regards the formalisation and the minimum elements of the agreement and the fee (which must always be reasonable, based on the nature of and Company may reimburse consultants for the expenses they incur in carrying out the activity provided for in the consultancy agreement.

When participating in tender procedures, it is necessary to:

• act in compliance with the principles of fairness, transparency and good faith;
• assess, when examining the call for tenders, the suitability and feasibility of the required performances;
• provide all the data, information and details requested during the selection of participants and the award of the tender;
• in the case of public tenders, maintain clear and proper relations with the public officials in charge, avoiding any conduct liable to compromise the freedom of judgement of the competent officials.

In the event the tender is awarded, in relations with the client it is necessary to:

• ensure that negotiating and commercial relations are conducted in a clear and proper manner;
• ensure the diligent fulfilment of contractual obligations.

In carrying out their activities on behalf of Lighthouse, all employees are required always to maintain a high degree of professionalism. All employees, moreover, in relation to their specific area of competence, are required to keep constantly up to date.

Personnel must treat with absolute confidentiality — including after the termination of the employment relationship — the data, information and details of which they come into possession. In particular, they must avoid disseminating such information or using it for speculative purposes of their own or of third parties.
Personnel must likewise treat with absolute confidentiality information and data relating to strategic roles, functions and sensitive processes, especially where these are functions and processes exposed to any form of external solicitation.
Personnel must treat with absolute confidentiality information relating to the processes for purchasing goods and services and information on debtors and all parties with whom negotiations have been initiated. Any information, data or document that employees become aware of during their work is the exclusive property of the Company; thus, by way of example and without limitation, every idea, formula, technique, invention, programme, business plan, marketing and sales plan and similar information constitutes confidential information and the exclusive property of Lighthouse.
It is therefore prohibited to disclose such information externally without express authorisation and to use it for one’s own personal advantage. Without prejudice to the prohibition on disclosing information relating to the organisation and production methods of the business, or on using it in such a way as to cause harm to it, each employee, in particular, must:

• acquire and process only the data necessary and appropriate for purposes directly attributable to the function performed;
• acquire and process such data only within specific procedures;
• store such data in such a way as to prevent unauthorised persons from becoming aware of it;
• communicate such data within predetermined procedures and/or upon explicit authorisation from superiors;
• ensure that there are no absolute or relative restrictions on the possible disclosure of information concerning third parties connected to the Company by a relationship of any nature and, where appropriate, obtain their consent.

Confidential information may be disclosed only to the OdV or to the Judicial Authority.

Personnel must protect and safeguard the values and assets of the Company entrusted to them, and contribute to protecting the Company’s assets in general, avoiding situations that may adversely affect the integrity and security of those assets.
In any case, Personnel must avoid using the Company’s resources, assets or materials for personal advantage or otherwise for improper purposes.

It is prohibited to set out, in the communications required by law to the public supervisory authorities and with a view to hindering the exercise of supervisory functions, material facts that do not correspond to the truth — even if subject to assessment — concerning the economic, financial or asset situation of the Company, or to conceal by other fraudulent means facts that should have been disclosed.

Addressees are required to behave in a correct, transparent and cooperative manner, in compliance with the rules of law and internal company procedures, in all activities aimed at preparing the financial statements and the other corporate communications required by law and addressed to shareholders or the public, in order to provide truthful and correct information on the economic, financial and asset situation of the Company. It is mandatory to strictly observe the rules laid down by law to protect the integrity and effectiveness of the share capital and always to act in compliance with internal company procedures, which are based on those rules, in order not to harm the guarantees of creditors and third parties in general.

Any liquidation operations of the Company must be conducted having regard to the overriding interest of the corporate creditors; it is therefore prohibited to divert corporate assets from their allocation to creditors, distributing them among the shareholders before payment of the creditors entitled or before setting aside the sums necessary to satisfy them. Furthermore, Lighthouse ensures the proper functioning of its corporate bodies, guaranteeing and facilitating every form of control over corporate management provided for by law as well as the free and correct formation of the shareholders’ meeting’s will; strict compliance with the internal procedures established for this purpose by the Company and/or, in any case, the adoption of conduct consistent with this principle is therefore required.

In particular, with reference to the preparation of the financial statements, the Company considers the truthfulness, correctness and transparency of the accounts, financial statements, reports and other corporate communications required by law and addressed to shareholders or the public to be an essential principle in the conduct of business and a guarantee of fair competition. This requires that the validity, accuracy and completeness of the underlying information for accounting entries be thoroughly examined. Consequently, no concealment of information or any partial or misleading representation of economic, financial and asset data by management and by those subject to their direction and control is permitted. Therefore, all collaborators, whether internal or external, engaged in producing, processing and recording such information are responsible for the transparency of the Company’s accounts and financial statements. Every transaction of economic, financial or asset relevance must be properly recorded, and for each entry there must be adequate documentary support.

In the course of its business, the Company is guided by the principle of protecting and safeguarding the environment and pursues the objective of guaranteeing safety and safeguarding the health of Addressees, through appropriate initiatives to this end.

The long-term objective is to drive operational incidents, accidents at work and environmental impact towards zero. The Company — autonomously, in compliance with legal provisions, or upon notification from any other source — adopts all the measures necessary to ensure and improve the conditions of the working environment, also and above all with reference to hygiene and safety arrangements, as well as procedures aimed at constantly improving the company climate. The Company is committed to complying with all the regulations and rules in force on the matter. Third parties who come into contact with the Company must cooperate to the best of their competence and responsibility in order to promote conduct aimed at guaranteeing the health and safety of workers. All Company personnel, within the scope of their duties, take part in the process of risk prevention, environmental protection and the protection of health and safety with respect to themselves, their colleagues and third parties.

In order to guarantee the transparency and correctness of commercial transactions and to avoid phenomena of money laundering (including in the form of self-laundering) and the handling of stolen goods, Personnel are required to:

• comply with the limits on the use of cash imposed by the legislation in force and by internal policies;
• draw up in writing — indicating the contents and the agreed economic conditions — the assignments conferred on any service companies or natural persons who look after the economic/financial interests of the Company;
• ensure, through the competent functions, that payments to all counterparties are duly made and verify that the party to whom the order is addressed coincides with the party that collects the relevant sums;
• carry out controls on financial flows relating to intra-group relationships;
• observe the minimum requirements set and required for the selection of suppliers;
• set the criteria for evaluating offers on the basis of the commercial and professional reliability of suppliers and partners, and request and obtain all the necessary information;
• comply with the obligations under Legislative Decree 231/07 and subsequent amendments or additions, taking particular care of client and beneficial-owner identification processes and adequately developing the assessment of the risks inherent in this sector.

In carrying out their professional activities, Personnel are required to use IT and telematic tools and services in full compliance with the relevant legislation in force (and in particular as regards computer offences, IT security, privacy and copyright) as well as internal procedures.
Personnel are prohibited from loading onto company systems borrowed or unauthorised software; it is also prohibited to make unauthorised copies of licensed programs for personal, company or third-party use.
The computers and IT tools made available by the Company must be used solely for company purposes; consequently, the Company reserves the right to verify that the content of computers and the correct use of IT tools comply with company procedures. Personnel are also prohibited from sending threatening and abusive email messages, as well as from using language not in keeping with the Company’s style or otherwise inappropriate language.

Personnel are prohibited from carrying out any form of incitement, promise, giving or offering of money or other benefit, directly or indirectly, of any kind, to a private party (suppliers, clients, agencies, business partners, consultants, etc.) aimed at the performance (or even the omission) of an act of their office, in breach of their professional and loyalty obligations, in order to obtain an advantage of any nature for the Company and/or for themselves and/or for third parties; this applies regardless of whether the act is subsequently carried out.
Likewise, it is prohibited to accept money or other benefit — whether economic or of any other nature — for the Company or for oneself or third parties, where such conduct is aimed at influencing the performance of an act of one’s office. It is possible to give or accept gifts of modest value, provided that company procedures are complied with and that the gift is not aimed at influencing, in any way, the conduct of the counterparty.

The members of the Corporate Bodies, Personnel and Third-Party Addressees are required to promptly report to the Supervisory Body any violations — even merely potential ones — of laws or regulations, of the Model, of this Code of Ethics, or of the internal Procedures of which they may become aware in the performance of their tasks and functions.

In any case, the following must be mandatorily transmitted to the Body:

A. Immediately, information that may relate to violations — even potential ones — of the Model, including, without limitation:

1) any orders received from a superior and considered contrary to the law, internal rules or the Model;
2) any requests for or offers of money, gifts (exceeding modest value) or other benefits coming from, or intended for, public officials or persons in charge of a public service or private parties;
3) any significant deviations from the budget or spending anomalies emerging from authorisation requests during the management-control reporting phase;
4) any omissions, negligence or falsifications in keeping the accounts or in storing the documentation underlying the accounting entries;
5) measures and/or information coming from criminal investigation police or any other authority from which it emerges that investigations are being carried out which concern, even indirectly, the Company, its employees or the members of the corporate bodies;
6) requests for legal assistance submitted to the company by employees pursuant to the applicable collective agreement, in the event criminal proceedings are initiated against them;
7) information relating to ongoing disciplinary proceedings and any penalties imposed, or the grounds for their dismissal;
8) any reports, not promptly addressed by the competent functions, concerning either deficiencies or inadequacies of the premises, work equipment or protective devices made available by the Company, or any other situation of danger connected with health and safety at work;
9) any violation, even potential, of environmental legislation as well as of the procedures issued on the matter by the Company;
10) any deviation found in the offer-evaluation process compared with the company procedures or predetermined criteria;
11) information relating to the existence of an actual or potential conflict of interest with the Company;
12) any critical issues regarding tenders — public or of public relevance, at national/local level — in which the Company has participated, as well as any critical issues regarding contracts possibly obtained following a private negotiation;
13) any accidents or illnesses causing an inability to attend to ordinary occupations for a period of at least forty days;
14) the critical issues resulting from the first-level control activities carried out by the various company functions involved in the offence-risk areas;
15) reports following inspections carried out by external supervisory bodies (e.g. local health authorities).

B. Periodically, as indicated below, information relating to the Company’s activity which may be relevant to the OdV’s performance of the tasks assigned to it, including, without limitation:

16) information relating to organisational changes or changes to the company procedures in force (every six months);
17) updates to the system of powers and delegations (quarterly);
18) a list of tenders, with regard to tenders — public or of public relevance, at national/local level — in which the Company has participated (quarterly);
19) decisions relating to the request for, disbursement and use of public funding (every six months);
20) the list of donations and gratuitous payments made to public parties (annually);
21) reporting on health and safety at work, and specifically the minutes of the periodic meeting under Article 35 of Legislative Decree No. 81/2008 (annually), as well as all data relating to accidents at work occurring at the Company’s sites (quarterly); information on the annual spending/investment budget prepared in order to carry out the necessary and/or appropriate improvement measures in the field of safety (annually); any updates to the Risk Assessment Document; and the competent doctor’s notification of anomalous situations found during periodic or scheduled medical examinations (every six months);
22) the annual financial statements, together with the explanatory notes, as well as the statement of financial position.

Communications to the OdV may be made, including anonymously, either by email (odvlighthousesta@gmail.com) or in writing to the address: Supervisory Body, c/o the registered office of Soc. LIGHTHOUSE S.T.A. SRL.

In any case, the OdV ensures that the person making the communication, where identified or identifiable, is not subject to retaliation, discrimination or, in any case, penalisation.