Organizational Model 231/2001

Cubi Srl has adopted an organization, management and control model pursuant to Legislative Decree 231/2001 and has adopted its own Code of Ethics.

CUBI Srl, in strict compliance with the primary corporate values, is in fact sensitive to the expectations of its customers, shareholders and employees as it is aware of the value that can derive from a system of safeguards suitable for preventing the commission of offenses by its own corporate bodies, employees, collaborators and business partners.

In this context, the Organization, Management and Control Model describes the system of behavioral rules that the company has adopted in order to prevent the commission of the various types of crimes contemplated by decree 231/2001, while the Code of Ethics contains the rules aimed at ensuring that the conduct of the recipients is always inspired by criteria of legality, correctness, honesty, collaboration, loyalty and mutual respect.

CUBI Srl at the same time appointed the Supervisory Body, an internal body with autonomous powers of initiative and control that monitors the functioning and observance of the established ethical principles and the provisions contained in the Organizational Model 231/2001.

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Ethical Code

Cubi Srl informs its internal and external activities of the principles included in the Ethical Code, which is considered an essential and functional element to the organizational model that the company follows according to the Italian Legislative Decree n.231 issued on June 8th 2001 and to the entire internal supervision system, with the belief that the ethics adopted when carrying-out business affairs also dictate the condition for success in business activity.

With the development of the Ethical Code, Cubi Srl aims to recognize the ethical values and principles that the company has always identified with, which are also shared and endorsed by the company’s operating personnel and suitable to prevent the risk of committing the felonies described in the Decree. In this context, by incorporating the contents of Confindustria’s (Federation of Italian Employers) guidelines, it endorses the principles of fairness and transparency that inspire Confindustria’s policy regarding the organization and conduct of business affairs.

For this purpose, beyond the search for performance and excellence that must guide the company’s activities, Cubi Srl aims to ensure high ethical standards in the strategic and daily conduct of its business. Considering the extent if its application and level of incisiveness on the organization and manner of conducting business activities, the Ethical Code is adopted by Cubi Srl through provision of the Sole Administrator.

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