Model 231

Code of Ethics and Model of Organization, Management and Control under Legislative Decree 231/01

By a resolution of the Board of Directors on March 9, 2022, Soleto S.p.A. adopted a Code of Ethics and an Organization, Management and Control Model pursuant to Legislative Decree No. 231 (hereinafter also "Model").

Through the Code of Ethics and the Model, Soleto S.p.A. intends to affirm and spread a culture marked by legality, transparency and fairness, reaffirming that no illegal behavior can be considered permissible, not even if committed in the interest or to the advantage of the Company itself.

More in detail, the Model adopted by Soleto S.p.A. provides a system of rules, organizational, management and control procedures, relating to each phase of the decision-making and operational processes of the company's business, aimed at avoiding the risk of commission of crimes. The Code of Ethics of Soleto S.p.A., on the other hand, collects the ethical principles and values that must shape the corporate culture and inspire the conduct and behavior of those who work in the interest of Soleto S.p.A., both inside and outside the corporate organization. The Code of Ethics is binding for all persons working in the Company without exception, as well as for external stakeholders in their contractual relationships with the Company.

Soleto S.p.A. aspires that all those who come into contact with the Company recognize themselves in the values on which the Code of Ethics is based and fully comply with the rules of the Model.
For this reason, Soleto S.p.A. ensures the widest dissemination, both internally and externally, of the Code of Ethics and the Model, and invites all its employees, Customers and Suppliers to read them at the following links

In order to reinforce the value of the principles and rules contained in the Model and the Code of Ethics, Soleto S.p.A., will include specific clauses in contracts with customers and suppliers, which will provide for the duty to comply with their content, also providing for specific contractual consequences in the event of their violation.

Soleto S.p.A. has activated a procedure that allows any bearer of interest of the Company (shareholders, employees, collaborators, customers, suppliers, etc.) to communicate, even anonymously, with the Supervisory Board to report problems related to the correct application of the Code of Ethics and the Organizational Model that the Company has given itself, in particular for the prevention of the crimes provided for in Legislative Decree 231/2001 concerning the administrative liability of Entities.
Reports are handled in a manner that ensures and respects the strictest confidentiality about the subjects and facts reported and, where desired by the reporter, the anonymity of the reporter's identifying information.
The Supervisory Board may contact the reporter if made possible by the reporter in order to acquire clarification and/or further details about the reported facts.
Reports can be sent by a letter addressed to the Supervisory Board or to the Board of Directors of Soleto S.p.A., at Soleto S.p.A., via Don Minzoni 1 - 20158 Milan. A Reporting Template is made available to the reporter.
In such a case, in order to take advantage of the guarantee of confidentiality, the report must be placed in a sealed envelope that bears the words "For the attention of the Supervisory Board, (or the Board of Directors or a member of the Board of Directors) confidential/personal" on the outside.