In order to detail and complete the rules of conduct of those who work directly or indirectly in the company Atena srl of Brisighella (hereinafter abbreviated as COMPANY), a Code of Ethics is drawn up which consists of the following articles whose content expresses the guidelines and the style of behavior to adopt and identify with.

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• The Code of Ethics is a voluntary corporate agreement, entered into between the COMPANY's shareholders, employees and external collaborators, in order to ethically regulate the relationships between them and between the company and its interlocutors, including those who, through collaborations of all kinds, allow it to achieve its institutional goals.

• The code is an effective means of preventing irresponsible or illegal behavior by those who work in the name or on behalf of the COMPANY, since it introduces a clear and explicit definition of ethical and social responsibilities towards all those directly or indirectly involved in the activity of the COMPANY itself. The Bodies of the COMPANY undertake to enforce the behavioral principles referred to in this Code of Ethics and by the reference standards in force. These principles, translated through the COMPANY's procedures and actions, must be respected by all recipients.

• The Code of Ethics applies to all subjects who are part of the COMPANY directly and indirectly. The provisions and principles of the Code of Ethics are therefore binding for the directors and all those holding corporate offices, for the shareholders, for the employees and collaborators and for all those who work for the COMPANY, whatever the relationship, even temporary. , which binds them to the same.

• These subjects, hereinafter collectively defined as "recipients" are required, without distinction and exception, to observe and enforce the principles identified below and to protect and preserve, through their conduct, the respectability and image of the COMPANY, as well as the integrity of its assets, understood as both tangible and intangible assets and resources.

The code of ethics will be published on the COMPANY's website and must be delivered, also in electronic form, to each new shareholder, employee and collaborator.

ETHICAL PRINCIPLES AND GENERAL REFERENCE VALUES

LEGALITY The COMPANY undertakes to comply with all national and international rules, laws, directives and regulations that regulate the activity of limited liability companies in Italy.

HONESTY: Honesty represents the fundamental principle for all the COMPANY's activities and constitutes an essential value of internal and external organizational management. Relations with stakeholders and collaborators are based on criteria and conduct of correctness, collaboration, loyalty and mutual respect.

TRANSPARENCY: The COMPANY undertakes to operate in a clear and transparent manner, without favoring any interest group or single individual. It pursues transparency within the organization, between partners, collaborators and towards the recipients of its activities. Each direct and indirect collaborator of the COMPANY is required to respect the principle of transparency within and towards third parties with whom he works in his name. The directors will do their utmost to ensure that all collaborators are always aware of the COMPANY's addresses and its "modus operandi" by providing precise, timely, clear and correct information.

RESPONSIBILITY TOWARDS THE COMMUNITY: The COMPANY, aware of its social role on the territory, undertakes to operate in respect of local communities also through initiatives that are able to combine the interests of individuals and that of the community

ENVIRONMENTAL PROTECTION: environmental protection is a cornerstone of the COMPANY's principles. The same and its partners undertake to maintain eco-compatible behavior in all the proposed activities with direct respect for the environment and also indirectly by selecting purchases, supplies and encouraging the reuse of materials and equipment.

ENHANCEMENT OF HUMAN RESOURCES: The COMPANY recognizes the central role of the person in all the activities that are carried out in the name and on behalf of the same. This recognition is realized in the respect of the human and artistic personality and of the professionalism that each collaborator brings within the COMPANY, in a framework of loyalty and trust and in respect of equal opportunities. All members and collaborators are required to contribute to the promotion and maintenance of a climate of mutual respect with particular regard to the sensitivity of each one.

EFFICIENCY AND QUALITY OF THE ACTIVITIES CARRIED OUT: The COMPANY undertakes to guarantee the performance of its activities by committing itself to achieving high quality standards compatible with its economic and human resources. Within the COMPANY, in order to achieve the right balance of efficiency and quality, the specific professionalism of each collaborator must primarily be promoted and valued. Furthermore, every activity and project must be carried out according to the principle of economy of management and of the resources used.

ATTENTION TO MEMBERS AND USERS: The COMPANY's style of behavior towards shareholders and third parties is based on availability, respect and courtesy, with a view to a collaborative and highly professional relationship.

CONFIDENTIALITY: The COMPANY ensures the confidentiality of the information in its possession and refrains from seeking confidential data concerning shareholders, collaborators and any other person it comes into contact with, except in the case of express and informed authorization and compliance with the legal regulations in force.

PROTECTION OF THE GOOD NAME OF THE COMPANY: In carrying out their activities, shareholders and collaborators must not commit actions capable of damaging or compromising the values listed in the preceding paragraphs, nor damaging the good name of the COMPANY, nor damaging its planning, i.e. activities that it carries out to achieve its goals.

CRITERIA OF CONDUCT OF THE COMPANY, ITS BODIES, SHAREHOLDERS AND ALL "RECIPIENTS"

HUMAN RESOURCES MANAGEMENT

In the management of its human resources (shareholders, collaborators, employees and those who perform a service on behalf of the COMPANY even free of charge, hereinafter generically referred to as "collaborators") it rejects any discrimination based on race, gender, nationality, religion, of language.

RELATIONS WITH THIRD PARTIES

The COMPANY believes in the validity of dialogue and in the importance of a dense network of relationships. In this regard, it undertakes to maintain friendly and constructive relations with all the realities of the territory: associations, public administrations, traders, other entities or individuals.

RELATIONS WITH THE PUBLIC ADMINISTRATION

Relations with the public administration must be initiated and managed in full compliance with the laws and regulations in force and based on clarity, transparency, collaboration and professionalism and on the recognition of their respective roles. In relations with public officials, the directors, employees and collaborators of the COMPANY must behave in a manner inspired by the utmost fairness and integrity, also avoiding giving the impression of wanting to improperly influence decisions or requesting preferential treatment. It is forbidden to receive / offer directly and / or indirectly money, gifts or benefits of any kind in a personal capacity to / from managers, officers and employees of customers, suppliers, Public Administration entities, Public Institutions and other Organizations for the purpose of derive undue advantages and influence the recipient's independent judgment.

DUTIES OF DIRECTORS AND OF THOSE HOLDING SOCIAL POSITIONS OR POSITIONS

The directors and those who hold corporate offices are required to comply with current legislation and the principles contained in this Code of Ethics, as well as in the Articles of Association. Their behavior must be based on principles of correctness, integrity and equity, also in order to protect the assets and image of the COMPANY. They must guarantee assiduous and informed participation in the life of the COMPANY. In the context of the activities carried out by the COMPANY, they cannot use their position to obtain personal, direct or indirect advantages and must avoid situations of conflicts of interest. In carrying out their mandate and, after the termination of the relationship with the COMPANY, they have the obligation of confidentiality on information regarding the COMPANY and its activities. It is forbidden for anyone holding the office of President, member of the Management Board of the Governing Council, general manager to hold administrative positions in political or trade union organizations, without promptly informing the COMPANY and asking for its opinion.

MANAGEMENT OF FINANCING AND PUBLIC CONTRIBUTIONS

The COMPANY must observe the principles of legality, transparency and correctness when requesting and managing grants and loans of any nature obtained from public bodies. To this end, the recipients of this Code of Ethics must:

• represent the interests and positions of the COMPANY in a transparent and rigorous manner;

• carry out a scrupulous check of the data contained in the declarations addressed to the supplying bodies;

The collaborators in charge of preparing the documentation necessary for participation in public tenders / notices or for the presentation of grant applications must:

• transmit truthful information;

• ensure the completeness and updating of such information;

• comply, in the transmission of the documentation, with the deadlines set by the public administration concerned.

The assumption of commitments with the Public Administration and Public Institutions is reserved exclusively for the designated and authorized functions, who will carry out their duties in due compliance with the laws and principles of this Code of Ethics.

SIGNING OF COMMITMENT AND ACCEPTANCE OF THE CODE OF ETHICS

Each member and collaborator reads and accepts this Code of Ethics, expressing the commitment not to hinder in any way the work of the bodies responsible for safeguarding its application.