CERTIFICATIONS

October 2, 2024

REINOVA S.p.A. Organisation, Management and Control Model (MOG)

‘Legislative Decree No. 231 of 8 June 2001 introduced into the legal system a system of administrative liability of Entities – including corporations – for certain offences committed by directors, managers or employees in the interest or to the advantage of the Entity itself.

Reinova S.p.A. has adopted its own Organisational Model with the aim of constructing a structured and organic system of guiding principles, operating procedures and other specific safeguards, inspired by criteria of transparency, correctness, loyalty and sound business management, aimed, among other things, at preventing the commission of the offences provided for in the Decree that may entail the administrative liability of the Company if committed in its interest or to its advantage.

The Model is divided into a General Part (containing the prescriptions of the Legislative Decree, the functions and objectives of the Model itself, the regulation of the duties of the Supervisory Body and information flows, the penalty system, general prevention protocols and the regulation of the Whistleblowing procedure) and into several Special Parts – one for each type of offence – which list the specific types of offences provided for by the Legislative Decree and the prescriptions to be observed to prevent the risk of their commission.

In accordance with the provisions of Article 6(1)(b) of the decree, the task of continuously supervising the adequacy and functioning of the Model 231, as well as of updating it by proposing amendments and additions, has been entrusted to the Company’s Supervisory Board (SB), which also takes care of updating it, submitting to the Board of Directors amendments and additions that become necessary in the light of regulatory or organisational changes or as a result of the actual implementation of the Model 231.

Below you can read and download:

a. the General Part of the Organisational Model;

bb. the Code of Ethics of Reinova S.p.A;

c. the Whistleblowing Procedure, available to anyone (employees, partners, customers, suppliers, consultants, collaborators, shareholders and, more generally, any Third Party) who intends to report to the Supervisory Board news concerning conduct in breach of laws and regulations and/or non-compliant the Code of Ethics, the Organisational Model and the system of company rules and procedures’.