1.1 These Guidelines are an excerpt of the control and management organization model pursuant to Legislative Decree 231/2001 ("Model 231") adopted by STI S.r.l. (hereinafter the "Company"). The Guidelines summarize the principles of conduct, the ethical rules and the rules of behavior that representatives of the Company’s boards, staff, collaborators, consultants and, in general, those who carry out work on behalf of the Company, are required to observe in carrying out their duties. 1.2 The rules indicated in the following points are binding for the Company’s staff and collaborators but also for suppliers, agent, associates, affiliates, lessees, shippers and other partners as well as the Company’s external service suppliers who shall therefore have to adopt and have a conduct that is compatible with the same. The Company shall not enter into or shall terminate contractual relations with parties that do not respect such principles. CONDUCT IN SENSITIVE AREAS PURSUANT TO LEGISLATIVE DECREE 231/2001 2.1 All parties indicated under point 1 (collectively also referred to simply as “Recipients”) must respect the existing laws and regulations that apply to the various sectors in which the Company carries out business. 2.2 The Guidelines: (a) Are a general principle of “work and business correctness and lawfulness". (b) Apply to the so called "sensitive areas", identified by the activities’ mapping exercise, where there is an abstract possibility that crimes pursuant to Legislative Decree 231/2001 are committed. Among the main sensitive areas identified by the mapping exercise, the following are especially noted: (i) Relations with the Public Administration (applications for authorizations, concessions, licenses, permits, payment of taxes, fees, concessions, duties, various excise duties, etc.); (ii) Daily management of the Company (registered office and administrative offices): relations with the P.A. (authorities, ASL, Firemen, local authorities, etc.); (iii) Applications for public funding (also in the form of tax benefits and tax abatements); (iv) Management of financial resources. Payment procedures and relations with banks and credit institutions; (v) Company management and shareholder relations; (vi) Human Resources (HR) management and, in particular, the adoption of safety and hygiene measures pursuant to Legislative decree no. 81/2008. Compliance with HSSE policies by different business units; (vii) Handling of relations with third parties (i.e. agents, associates, affiliates, lessees, shippers, distributors, suppliers, and other commercial partners); (viii) Handling of so-called privileged information concerning IMI Group companies listed on the European and International stock markets; (ix) Management of the Information system and of IT procedures; (x) Environmental area. (c) In summary, these Guidelines are the rules of ethics and behavior inspiring the conduct of persons who carry out work for IMI Group comp

GENERAL PRINCIPLES OF CONDUCT OF THE IMI GROUP 3.1 Each company of the IMI Group has adopted and incorporated the Code of Conduct – IMI Way ("IMI Way") which summarize the ethical principles that need to inspire the conduct of its boards, staff, collaborators and consultants. 3.2 The IMI Way identify the main areas of responsibility for shareholders, clients, staff, commercial partners and the community. Such rules need to be considered as priorities also for the Recipients carrying out of activities. 3.3 Within the scope of each area of responsibility the underlying objectives to be pursued...

(c) transparency and reliability of recordings and reporting relating to the management and treatment of public funding; (d) integrity and correctness in the use of public funding disbursed to companies of the IMI Group, ensuring that the same is used for the purpose and in the manner for which it was made available; (e) correctness in carrying out the specific checking activities on the formal and substantive regularity of operations carried out after funding has been received; (f) respect of existing regulations and of the instructions supplied by the competent Administrations. PROPER MANAGEMENT...

(a) observance of provisions of law, regulations, company by-laws, and internal procedures and regulations relating to company bodies and corporate and financial operations of the Company; (b) correctness, completeness, transparency, lawfulness and integrity of the data and accounting records of the Company; respect of laws, regulations and internal rules on the preparation of the Company’s accounts, and of all economic and financial documents in general; (c) lawfulness, correctness, completeness and transparency of relations with the control auditing authorities; (d) transparency, correctness,...

8.2 Recipients are obliged to respect the laws on immigration and in particular they are obliged not to recruit people coming from third countries, who are not in possession of a regular permit of staying. 8.3 Recipients are obliged to respect the laws on environment protection, with particular reference to waste and polluting material management. 8.4 Recipients need to strictly observe the Company’s policies and/or procedures, which define, for each business unit – depending on the type of work carried out and assessment of the risks connected with such work – the structure, responsibility,...

9.3 The following is also requested: (i) Objectiveness in the selection of suppliers and commercial partners and in the drafting of contractual conditions. (ii) Respect of the principles of lawfulness, correctness and transparency in activities and relations involving third parties, being them public or private entities. (iii) Respect of functional authorities in relation to expenditure powers and the observance of internal procedures governing purchasing and payments. 9.4 The Company reserves the right to terminate contracts with third incompatible with the IMI Way and with these “Model 231”...