Code of Ethics and Organization and Management Model Legislative Decree No. 231/2001

ADMINISTRATIVE LIABILITY OF COMPANIES (D. LGS. 231/01)

The Legislative Decree no. 231/2001 on the "Administrative liability of legal persons, companies and associations with or without legal personality" introduced for the first time in the Italian legal system the principle of company’s criminal liability of legal entities for offenses committed in the interest or for the advantage of the organization itself. 
The Legislative Decree and subsequent amendments and additions are applicable to several categories of crimes, including crimes committed in detriment of the Public Administration, corporate offences, offences committed in breach of occupational safety rules, environmental and IT crimes.

The Company reaffirms its commitment to the active prevention of crimes, in particular by adopting the following:

· A "Code of Ethics" which expresses clearly the general ethical principles and the reference values or rules of behavior towards the main stakeholders, who all corporate entities have to comply with, regardless of whether they are employees, collaborators or directors;

· A "Model of organization, management and control pursuant to Legislative Decree 231/01", defining the guidelines for an appropriate system of corporate control, the general principles and the specific controls to prevent the commission of crimes, which all Company members, especially top managers, have to comply with.  
 
Besides, the Company has established and appointed a Supervisory Board pursuant to Legislative Decree 231/01, mainly with tasks of supervising the operation of the Model, its adequacy and any possible upgrade opportunities.

Contacts:
Supervisory Board pursuant to Legislative Decree 231/01 Lonati SpA
Tel. 030.23901
Via Francesco Lonati, 3-25124 Brescia (BS)
odv@lonati.com