Organizational Model D. LGS 231/01

On July 24, 2018, the Board of Directors of Industria Chimica Panzeri S.r.l. adopted an Organization, Management and Control Model (MOG 231) pursuant to Legislative Decree 231/01 on the administrative liability of legal persons, companies and associations, including those without legal personality, the primary purpose of which is to prevent the commission of unlawful conduct by its directors, employees and collaborators in various capacities through compliance with prevention protocols designed to limit the potential risk of occurrence of the predicate offenses covered in Catalogue 231. The Model consists of a General Part, downloadable from the link below, which outlines the principles, composition, architecture and purpose of the Model, and a Special Part where for each crime the relevant prevention protocols aimed at minimizing the risk of occurrence of the crime itself are identified. The Model is governed by the Supervisory Board, an entity endowed with autonomous powers of initiative and control, which is responsible for supervising the operation of the Model, ensuring its effectiveness and adequacy, and ensuring that it is periodically updated. The Supervisory Board of Industria Chimica Panzeri consists of 3 members, two of whom are external and one internal. All recipients of the Model are required to report to the Whistleblowing Committee any violations of misconduct relevant under Legislative Decree June 8, 2001, no. 231 or violations of the OMC 231 using one of the following internal reporting channels activated by the Company:

  1. reporting in written form using functions of the dedicated online platform;
  2. reporting in written form on analog (paper) media;
  3. Communication in oral form.

All information on the aforementioned internal reporting channels and the procedures and prerequisites for making internal reports, as well as the channel, procedures and prerequisites for making external reports, can be found in the “Regulations on the Handling of Reports of Misconduct and the Protection of Reporting Persons (Whistleblowing)” published in the whistleblowing section of the company website https://www.chimicapanzeri.it

Code of Ethics

Message from the CEO

our Society has chosen to define the values and sense of responsibility that characterize our operations, both internally and externally. The main goal is to responsibly guide our behavior in our relationships with customers, the market, and the people who work with us. Our values and principles now find their synthesis in this Code of Ethics, which becomes our ‘Ethics Charter’ for all of us and all of our stakeholders. To this end, we will also be assisted by the Supervisory Board, as the Guarantor Body which is also assigned the task of supervising the application of the Code of Ethics. We will have the opportunity to communicate with that body to seek clarification of behavior that may be contrary to the purpose and values of the society, or to current regulations, and to propose improvements. All recipients of this Code of Ethics have, in addition, the opportunity to report conduct, acts or omissions that harm the public interest and the integrity of the Company (“illegal conduct”) pursuant to Legislative Decree 24/2023 to the Whistleblowing Committee through the internal reporting channels activated by the Company, which guarantee the confidentiality of the identity of the person reporting, the person involved and the person in any case mentioned in the report, as well as the content of the report and the related documentation. I urge you to read carefully and share the core values that inspire our ‘Charter of Ethics’.

Thank you all. The CEO of Industria Chimica Panzeri Andrea Panzeri