ANTI CORRUPTION GUIDELINES

Anti-corruption Guidelines

The Global Competitiveness Report prepared by the World Economic Forum identifies corruption as a major barrier to doing business, which exposes organisations to the risk of failing to achieve their operational, reporting and compliance objectives and poses a significant threat to sustainable growth, stability and free market competition. In recent years, problems relating to corruption have played an increasingly important role at international level, with a steady increase in the penalties associated with violations of the key legislation. Persons (individuals, legal entities and de facto entities) that violate Anti-Corruption Laws may be subject to fines, disqualifications and imprisonment depending on the persons involved, seriously damaging the Company’s reputation. In line with the actions taken by governments, which have established a regulatory framework designed to discourage corrupt practices, both at local level and through international agreements, organizations must, in turn, seek to actively contribute to combatting corruption. In this respect, Altergon Italia S.r.l. Unipersonale (below also the “Company”, or “Altergon”) is committed to operating in all geographic areas with honesty, integrity, and ethics, and in compliance with the highest anti-corruption standards.

In this context, and in view of the increasingly important role played by Altergon at international level, it is considered appropriate to adopt these “Anti-Corruption Guidelines” (below also the “Guidelines”), in addition to the governance tools and guidelines already formalized. The aim of these Guidelines is to establish a systematic framework for combating corruption and to disseminate the principles and rules within Altergon, that must be followed to prevent corrupt conduct of any kind, either direct or indirect, in the form of incitement, and, more generally, to ensure compliance with the provisions of the applicable Anti-Corruption regulations.