TESEO SpA carries out its activities according to a vision of corporate social responsibility based on values of accountability, ethics, integrity, fairness, transparency and legality in the awareness that this reflects on the objectives and reputation of the Company and the Group, generating value and meeting the highest expectations of its stakeholders.

TESEO SpA encourages and promotes the dissemination of a corporate culture based on ethics and integrity and inspired by the principle of “zero tolerance for corruption”.

The Code of Ethics represents the common basis of the fundamental values and standards of conduct of TESEO SpA and the compass that must guide the behaviour of all those within the Group (corporate bodies, management, employees) and of all those who, directly or indirectly, permanently or temporarily, establish relations and relationships with TESEO SpA.

Integrity and honesty are fundamental values enshrined in the Code of Ethics of TESEO SpA, which manifests its commitment to act in full respect of legality and transparency and to repudiate and discourage all forms of corruption - at whatever level practised, both in Italy and abroad - or abuse.

The Organisational, Management and Control Model pursuant to Legislative Decree no. 231/2001 consists of a series of rules, protocols, tools and conducts, functional to provide TESEO SpA with an effective and adequate organisational, management and control system capable of identifying and preventing the risks of committing offences pursuant to Legislative Decree no. 231/2001 by persons of the entity or functionally linked to the entity in the interest or to the advantage of the Company itself. The adoption and effective implementation of Model 231 is the essential condition for exemption from administrative liability of the entity pursuant to Legislative Decree No. 231/2001.

TESEO SpA is committed to promoting a corporate culture based on ethical behaviour and good corporate governance, thus fostering an environment in which People are encouraged to report unacceptable conduct within the Company.

The discipline of so-called “Whistleblowing”, introduced into the Italian legal system by Legislative Decree 24/2023 in order to fight possible corruptive events in the workplace, provides specific protection for the whistleblower who wishes to communicate, disclose or report an offence, so that such persons may act without fear of suffering prejudicial consequences against them.

This information notice is addressed to all persons who deal with TESEO SpA and for whom the protections - provided for by Legislative Decree 24/2023 - apply should they decide to report any corporate wrongdoing in which they were directly involved or of which they became aware.

The process complies with the regulatory changes introduced by Legislative Decree No. 24 of 10 March 2023 implementing Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law and laying down provisions concerning the protection of persons who report breaches of national provisions of law.

The process of managing reports is an integral part of TESEO SpA's Organisation, Management and Control Model pursuant to Legislative Decree no. 231/2001.

For sending and managing reports, TESEO SpA has implemented a dedicated web platform managed by an external company, which is the preferred channel for sending reports. Data are therefore neither transferred nor managed through the servers of TESEO SpA or other Group companies. This ensures that reports cannot be traced and that the data is always protected.

Reports should be submitted using the following link: www.teseo.wallbreakers.it

The mentioned channel cannot be used to file a complaint regarding the business relationship, but only to report unlawful conduct.

It should be noted that in Italy, in implementation of Legislative Decree 24/23, the National Anti-Corruption Authority (ANAC) has been identified as the authority responsible for receiving and handling external reports, also in anonymous form.

The reporting person may therefore make an external report to ANAC if, at the time of its submission, one of the following conditions is met:

• has already made an internal report and the report has not been followed up;
• it has justified reasons to believe that, if it were to make an internal report, the report would not be effectively followed up or that the report might lead to a risk of retaliation;
• has justified reason to believe that the breach may constitute an imminent or obvious danger to the public interest.

Moreover, the reporting person may also turn to ANAC to notify any retaliatory acts resulting from a report.

Reports outside the ANAC can be made according to the procedures set out on the institutional website of the body: www.anticorruzione.it

CODE OF ETHICS AND CONDUCT