ORGANISATION, MANAGEMENT AND CONTROL MODEL ("231/2001 MODEL")

Bora S.p.A. adopted the “Organisation, Management and Control Model” (below the “231/2001 Model”) in compliance with the Legislative Decree 231/01, which contains provisions governing the administrative liability of legal entities, companies and associations also without legal status.

Bora’s 231/2001 Model is a document divided into a General Section and a Special Section. The first section looks at the regulations contained in the Decree and constitutes the guidelines setting out the process of adoption of the 231/2001 Model by Bora S.p.A., the addressees of the 231/2001 Model, the methods of adoption and implementation of the 231/2001 Model, the Supervisory Board, the penalty system for breaches, and the disclosure and staff training requirements for the 231/2001 Model. The second section identifies the significant crimes for Bora S.p.A. and the corresponding sensitive business activities, the essential control measures designed to prevent and mitigate the offences and the specific protocols. Special Section of Bora S.p.A.’s 231/2001 Model is composed by the following Special Parts:

1. Crimes against the Public Administration;
2. Crimes against industry and trade and copyright offences;
3. Corporate crimes;
4. Crimes of manslaughter and serious injury;
5. Environmental crimes;
6. Illegal employment of foreign nationals;
7. Tax crimes.

Bora S.p.A. adopted the “Ethical Code”, which is part of 231/2001 Model.

Bora S.p.A. appointed a Supervisory Board composed by a single member, Mr. Giovanni Scrofani. Supervisory Board must verify the efficiency and effectiveness of the 231/2001 Model, promoting the update of the document.

Unlawful conduct relevant to Legislative Decree 231/2001 must be reported to the Supervisory Board through specific email addresses.

• odv@bora-italy.eu
• whistleblowing@bora-italy.eu

or by post to:
Supervisory Board
Bora S.p.A.
Via dell’Industria n. 3
60030 Maiolati Spontini – Fraz. Moie AN
CONFIDENTIAL