Organization, Management and Control Model and Code of Ethics

Organisation, Management and Control Model pursuant to Leg. D. 231/2001 and Code of Ethics

AdB has long adopted an Organisation, Management and Control Model with the aim of guaranteeing an internal Control System in order to prevent any illicit conduct, while maintaining correctness and transparency in the business performance and corporate activities, in the safeguard of the corporate image, the associates' expectations and the employees work.

This Model integrates with the principles and terms of the Code of Ethics and the Anticorruption Policy.

AdB's BOD appointed a 231 Surveillance Body which has independent powers of intervention and control, with the task of supervising the performance and respect of the Model, including the Code of Ethics, and of pursuing its updating.

In order for ethical principles to be given the right priority, AdB's BoD has approved an Ethics and Anticorruption Committee that will back the Surveillance Body while dealing with all 'anticorruption' aspects, with the task of monitoring and evaluating the effective performance of the Anticorruption policy as well as its compliance.

Reporting

All the addressees of the Model are asked to promptly report any breach to the Surveillance Body and are as well expected to inform the Body about any official acts against them.

Any reporting of breaches of the Model must be sent to the Surveillance Body in writing.

In addition to the abovementioned breaches, it is possible to report reasonable and honest suspicions about any illicit deeds, frauds, perils, workplace bullying and harassment or other serious hazards that might endanger clients, colleagues, stakeholders, the public in general or the society's reputation, according to what is contained in the Whistleblowing Policy.

In both cases the society guarantees the confidentiality of the reporter's personal data, apart from those reportings done in bad faith.

The reporter can use the IT platform dedicated to the collection and management of any breaches or wrongdoing:

• Platform Whistleblowing

In case the report affects the AdB Internal Audit functions, or the Internal Audit function has any potential interest connected with the report such as to compromise the fair and unprejudiced handling of the issue, the reporter may select the specific case on the platform.