231 ORGANIZATIONAL MODEL

The Legislative Decree of June 8, 2001, entitled "Discipline of the administrative liability of legal persons, companies and associations, including those without legal personality" ("Decree"), introduced into the Italian legal system a special regime of administrative liability for Entities for certain crimes committed, in the interest or to the advantage of the same, by directors, managers or employees. This liability is in addition to that of the natural person who materially carried out the act.

The Company, sensitive to the need to ensure conditions of fairness and transparency in the conduct of business and corporate activities, to protect the expectations of its stakeholders and the work of its employees, in accordance with the provisions of Article 6 of the Decree, has adopted an Organization and Management Model ("Model") aimed at preventing the commission of the various types of offenses contemplated. The Model, published for transparency purposes in this section, aims to regulate the conduct of the parties involved through the construction of a structured set of rules of conduct, protocols and procedures.

THE CODE OF ETHICS

The Company has adopted its Code of Ethics in which the values that inspire the Company in conducting its business and achieving its objectives are defined, also for the purpose of preventing the crimes provided for in the Decree. For the concrete and effective implementation of the Model and compliance with the Code of Ethics, a Supervisory Board ("SB") has been established, endowed with operational autonomy, to which the Company has entrusted the task of supervising compliance with the Model, as well as taking care of its updating.

The SB can be contacted at the dedicated e-mail address odv231@epassi.com

WHISTLEBLOWING

In order to prevent and counter unlawful behavior that is not in line with its values, the Epassi Group has adopted a general discipline, contained in the "Epassi Group Whistleblowing Policy ", concerning how to make reports of perceived or detected wrongdoing.

In compliance with the specific legal obligations set forth in Legislative Decree No. 24/2023, the Company has adopted its own procedure governing the receipt, management and investigation of reports of unlawful conduct identified in the aforementioned Legislative Decree. Legislative Decree No. 24/2023. To this end, the Company has made the reporting channels accessible to all its employees and users of the website through the procedure contained in the document "Reporting_Canal Whistleblowing" available and viewable in this section. Reporting can be done through the channel made available by theEpassi Group(Epassi Whistleblowing Channel).

The objective is to prevent the realization of non-compliance or irregularities within the organization, but also to involve all stakeholders in an activity to combat illegality, through active and responsible participation.

Regardless of the reporting channel used, the protection and confidentiality of the identity of the reporter and the reported person is always guaranteed, in accordance with applicable laws. If the report turns out to be false, unfounded and/or made for the sole purpose of harming the person being reported, or aimed at reporting situations of an exclusively personal nature and outside the perimeter of the provisions of the law, it will not be taken into consideration.

SUSTAINABILITY, QUALITY AND ENVIRONMENT

The Company is aware of the importance of the social contribution of the business activity and intends to pursue the pursuit of competitiveness in the market through the correct and functional use of its resources, going beyond compliance with purely economic requirements and in full respect for the quality of the environment and the social system, also in order to increase its ability to produce value and create well-being for the community.

In this context, the Company has set precise goals to achieve results of excellence. These objectives, which are the basis of the Integrated Management System implemented, are formalized in the "Quality and Environmental Policy" document available and viewable in this section.

IMPACT REPORT

As of 2021, the Company transformed into a Benefit Society (SB), embracing an even more evolved way of doing business and embarking on a path of further growth and commitment to sustainability and inclusiveness goals, to bring concrete benefits to the reality in which it falls and, in general, to those around it. After its transformation into a Benefit Corporation, the Company continued its evolutionary process by obtaining B Corp. certification in early 2023.

The objectives identified as well as the measurement of their degree of achievement are formalized within the Impact Report, a document through which the Society is committed to recounting the progress of the objectives included in the charter and finding new ways to personally commit to a sustainable future.

CODE OF CONDUCT FOR SUPPLIERS

The Company is aware that a company's success is measured through a combination of several factors, not only economic, and places great emphasis on ensuring that its activities are carried out with integrity and professionalism, pursuing high ethical standards and complying with local and international regulations.

Suppliers are a fundamental and essential part of the Company's business and therefore, for any strategy or path, their participation is necessary.

The Code of Conduct is addressed to all those who work in collaboration with the Company and is intended to define the guidelines of behavior to be adopted every day in the management of their work activities.

UNI/PdR 125:2022 CERTIFICATION - GENDER EQUALITY.

The Company is committed to incorporating the principles of gender equality, articulated over the entire career path and life stages of female workers, from the time of recruiting to retirement, with the aim of not only increasing the presence of women within the work environment but also ensuring equal career opportunities, up to the most important apical roles, equal economic treatment, work-life balance conditions appropriate to the different stages of life and proactive in the rebalancing of family loads between men and women, as well as a work environment that rejects stereotypes, discrimination, all forms of physical, verbal, and digital abuse and instead proposes a culture of diversity and inclusion.

The Company is certified according to UNI/PdR 125:2022, an Italian reference practice that defines guidelines on the management system for gender equality and provides for the structuring and adoption of a set of performance indicators (KPIs) inherent to gender equality policies. This certification testifies to the Company's adoption of a structured and measurable approach geared toward monitoring and improvement over time.

RELATED DOCUMENTS

• 231 Model (Italian version)
• Code of Ethics (English version)
• Quality and environmental policy (Italian version)
• Impact report (Italian version)
• Code of conduct for suppliers (Italian version)
• Gender Equality Policy (Italian version)
• Gender Equality Strategic Plan (Italian version)
• Whistleblowing channel reports (English version)