MOGC PURSUANT TO D.Lgs 231/01

ORGANISATIONAL, MANAGEMENT AND CONTROL MODEL, AS PROVIDED BY LAW N. 231 OF 2001.

GUNA is aware of the need to ensure fairness and transparency in the conduct of business and corporate activities, and since 2009 has adopted a Code of Ethics, which encompasses the values, principles, behavioral guidelines that inspire the whole corporate activities, and that applies to the Company’s directors, auditors, employees, contractors, consultants, all those freelancers who work for the Company and other third parties, whether they are suppliers or customers.

To further strengthen the company’s control tools, although the implementation of an Organizational, Management and Control Model pursuant to Legislative Decree no. 231/2001 is provided for by law as optional and not compulsory, GUNA has willingly adopted a regulatory system which may constitute a valid instrument for anyone who work in the name and on behalf of Guna, and drive them to behave correctly and consistently, whenever they perform their activities, so as to prevent the risk of committing any offenses provided for by the Decree itself.

The Organizational, Management and Control Model has been approved by a resolution of the Board of Directors on January 15, 2016. To monitor the implementation of the Model, the Board of Directors has also appointed a Supervisory Body responsible for overseeing its actual enforcement, efficiency and compliance over time. Any notification of alleged infringement of this model can then be forwarded to the email box odv@guna.it or via regular mail at: Guna S.p.A. – Supervisory Body for Model 231 Via Palmanova 71-20132 Milan