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 recipients of the Model are required to promptly report any breaches of it to the Supervisory Body, and are also required to inform the Supervisory Body of any official proceedings brought against them.

In addition to the breaches mentioned above, reasonable and genuine suspicions related to possible offences, fraud, dangers, episodes of workplace harassment and mobbing or other serious risk that might threaten customers, colleagues, stakeholders, the general public or the company's reputation according to what is set out in the Whistleblowing Policy can be reported.