Organisation, Management andControl Model in accordance with
Italian Legislative Decree no. 231 of 8June 2001- GENERAL PART-INTERNAL Datalogic Confidential

CONTENTS
1. Italian Legislative Decree no. 231/2001 – Preamble.

p. 5

1.1 (continues): The adoption of the Model as a possible exemption from liability.

p. 6

1.2 (continues): Liable offences.

p. 8

1.3 (continues): Penalties.

p. 8

1.4 (continues): Model suitability.

p. 9

2. GROUP STRUCTURE – Preamble.

p. 9

2.1 (continues): Datalogic S.r.l.

p. 10

2.2 (continues): Datasensing S.r.l.

p. 10

2.3 (continues): Datalogic IP TECH S.r.l.

p. 11

2.3 (continues): Datalogic Group and administrative liability as per Italian Legislative Decree
231/2001.

p. 11

3. CORPORATE GOVERNANCE

p. 11

4. THE DATALOGIC MODEL – Preamble.

p. 12

4.1 (continues): Role of the Model.

p. 14

4.2 (continues): Mapping of at risk activities.

p. 14

4.3 (continues): Control principles and preventive control systems.

p. 15

5. MODEL AND CODE OF ETHICS

p. 17

6. THE SUPERVISORY BODY – Preamble.

p. 17

6.1 (continues): The composition of Datalogic’s Supervisory Body.

p. 19

6.2 (continues): Roles and powers of Datalogic's Supervisory Body.

p. 20

6.3 (continues): Reporting from the Datalogic Supervisory Body.

p. 21

7. INFORMATION FLOWS TO EMPLOYEES

p. 21

8. INFORMATION FLOWS TO THIRD PARTIES

p. 22

9. DISCIPLINARY SYSTEM - Preamble.

p. 22

9.1 (continues): Employee penalties.

p. 23

9.2 (continues): Manager penalties.

p. 24

9.3 (continues): Penalties for the members of the Board of Directors and Board of Statutory
Auditors.

p. 24

9.4 (continues): Third party measures.

p. 25

10. REPORTING.

p. 25

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2

DEFINITIONS

At-risk activities

National Collective Labour Agreement

A process, a transaction, an act or a set oftransactions and acts that may expose
Datalogic to a risk of offences
National Collective
applied by Datalogic

LabourAgreements

Code of Conduct

Corporate Code of Conduct for listed
Companies, in its most recent version
approved in 2015, issued by the Corporate
Governance Committee and promoted by
Borsa Italiana, the complete text of which isavailable
on
the
web
site
www.borsaitaliana.it

Code of Ethics

The Code of Ethics adopted by the Groupand approved by the Datalogic Board of
Directors on 4 November 2009, as amended,
the complete text of which is available atwww.datalogic.com

Consultants

Parties that act in the name and/or on thebehalf of Datalogic pursuant to an agency
contract or another professional service
contract

Datalogic

Datalogic S.p.A., headquartered in Calderara
di Reno (Bologna) on Via Marcello Candini
no. 2, resolved, subscribed and paid-in sharecapitalEUR30,392,175.32,
Bologna
Company Register enrolment number andtax code 01835711209, Administrative andEconomic Index no. BO-391717

DecreeItalian Legislative Decree no. 231 of 8 June
2001, as amended

Addressees

Corporate bodies, Employees, Consultants,
Partners and Suppliers

Employees

Persons with an employment or coordinatedand continuous contractual relationship with
Datalogic, including managers

Suppliers

Suppliers of goods and services to Datalogic
which are not classified as Partners

Group

Datalogic S.p.A. and its subsidiaries or
associates

Offences

Administrative offences consisting of abuseof inside information (art. 187-bis TUF Consolidated Law on Finance) and market
manipulation (art. 187-ter TUF) for which an
appreciable risk level was identified asregards the activities carried out by Datalogic

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3ModelOrganisation, Management and Control
Model adopted by Datalogic, in accordancewith articles 6 and 7 of the Decree

Corporate Bodies

Datalogic's Board of Directors and Board of
Statutory Auditors

Supervisory Body

The collective body within Datalogic incharge of supervising the implementation ofand compliance with the Model, as well as its
updating

Partner

Contractual
counterparty(including
customers) with which Datalogic has
established a contractually governed
relationship, and which will work together
with Datalogic in the area of at-risk activities

General Part

The section of the Model containing, among
other things, the description of the role ofthe Model and of the Supervisory Body, as
well as a description of Datalogic and theGroupSpecial Parts

The parts of the Model expressly dedicatedto each Crime and Offence, which also set
forth the relative prevention procedures

Public Administration

The public administration and, for offences
related to the public administration, public
officials and public service employees

Crimes

The type of crime to which theadministrative liability regulations set forthin the Decree apply. The Model considers
only the crimes for which an appreciable risk
level has been identified within Datalogic's
business

Consolidated Law on Finance (TUF)

Italian Legislative Decree no. 58 of 24
February 1998 - "Consolidated Law offinancial intermediation provisions"- assubsequently supplemented and amended

ORGANISATION, MANAGEMENT AND CONTROL MODELDATALOGIC S.P.A.

INTERNAL Datalogic Confidential41. Italian Legislative Decree no. 231/2001 – Preamble.
In execution of the mandate pursuant to Italian Law no. 300 of 29 September 2000, on 8
June 20011, the Italian government issued Italian Legislative Decree no. 231/2001
containing the "Provisions on Administrative Liability of legal persons, companies andassociations, also without legal personality", which updated Italian law in relation to theliability of legal persons on the basis of some International Agreements previously
signed by the Italian government2.
The Delegated Legislator has introduced into the Italian legal system an autonomous
liability system applicable to entities, for offences following the committing of crimes (tobe added to the liability of the physical person who has materially committed them),characterised by presuppositions and consequences other than those expressly set forthin terms of the criminal liability of the physical person.
Therefore entities may be held responsible if, before a crime is committed by a subject
associated therewith (see infra), they had not adopted and effectively implemented
their own organisational and management model capable of avoiding crimes of the typethat was committed.
In particular, the entities may be held liable about the offence if the crime wascommitted:(i)by physical persons carrying out representative, administrative or management
functions for said entities or for one of their organisational units holding financial
and functional autonomy; by physical persons who carry out, de facto orotherwise, the management and the control of said entities (i.e. subjects in a top
corporate position) as well as by(ii)

by physical persons under the management or supervision of one of the subjects
listed at point sub (i) (i.e. subjects in a subordinate position).

This liability applies in addition to the liability of the natural person who actually
executed the deed.
In order to hold the company liable, it is also necessary that the assumed unlawful
conduct of the identified subjects was carried out “in the interest or to the advantage of
the Company”3, whereas said liability is expressly excluded if the crime was committed“in the perpetrator's own or in a third party's exclusive interest”.

1 In force as of 4 July 2001.
2 OECD (Organisation for Economic Cooperation and Development) convention of 17 December 1997 on thebribery of foreign public officials in international business transactions. OECD and European Union
conventions against bribery in international commerce and against fraud to the detriment of the European
Community. In particular, art. 11 of the Delegate law (Italian Law no. 300 of 29 September 2000) delegated
the government to regulate this type of liability.
3As regards the liability for crimes committed by legal entities and by companies, the provisions of the law,based on the assumption that the crime was committed “in the perpetrator's own interest or advantage”,
do not contain a hendiadys because the terms refer to two legally different concepts with a distinction
made between an upstream interest related to an undue enrichment, envisaged ex ante but possibly nevermaterialised, following the unlawful act, and an advantage that was objectively achieved by committing the
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5More precisely, the Court of Cassation has stated that the entity is not liable for an
administrative offence that depends on a crime since the act was committed by asubject in its own or third party's interest, not even partially connected with the interestof entity, or if it is not possible to configure an identification between the company andits corporate bodies. Except for the above, the entity does not recognise liability forwhat its employee/representative has committed if it can demonstrate to have adopted
the necessary measures to avoid the type of offence that was committed (adoption andeffective implementation of the Model).
The case law has also pointed out that the liability attributed to the entity by Italian
Legislative Decree 231/2001 results from a “negligent act within the organisation” of thelegal entity (ex plurimis, Criminal Court of Cassation, Section VI, 18-02-2010 - 16-072010, n. 27735). The non-adoption of the Model, in the presence of the objective andsubjective conditions described above (offence committed in the interest and for theadvantage of the company, and senior management position of the perpetrator of theoffence) is sufficient to constitute that kind of blameworthiness, mentioned in the
Ministerial Report transposing the Legislative Decree, and to represent a situation
subject to sanctioning due to the omission of the set forth organisational andmanagement precautions for the prevention of some types of crime. The concept of
blameworthiness implies a new “regulatory” form of culpability for organisational andmanagement omission, since the legislator has already reasonably deduced from actual
facts that have occurred in recent decades, within an economic and management scope,
the legitimate and grounded conviction of the necessity that any organisational
structure constituting an entity, ex art. 1, paragraph 2 of Italian Legislative Decree
231/01, adopts organisational and management models designed to prevent thecommission of certain offences, which experience has demonstrated to be functional tostructured and consistent interests4. This “organisational culpability” assumes specificrelevance within the scope of a group of companies.
1.1 (continues): The adoption of the Model as a possible exemption from liability.
However, in introducing the aforementioned system of administrative liability, art. 6 of
the Decree sets forth a specific form of exemption from said liability if the entity candemonstrate that, in the case of an offence committed by subjects in a senior
management position:a) the executive body of the entity had adopted and effectively implemented5, before
the act was committed, an organisational and management model designed toprevent the liable offences of the type that occurred;crime, although not predicted, so that the interest and the advantage are actually linked. Court of Cassation,
Section II, 20.12.2005 no. 3615. The requirement of the interest or advantage of the entity, as a criterion for
objective attribution of liability to the entity itself, can also certainly include an indirect advantage, intended
as an acquisition for the company of a privileged position in the market resulting from the crime committed
by a senior management subject. Nevertheless, the nature of the liability attribution criterion as recognisedby the law, requires a concrete, and non-abstract assertion of the existence of such interest or advantage, tobe understood respectively as a potential or actual usefulness, although not necessarily of an equity nature,deriving to the entity from the commission of the liable offence. Court of Milan – Order of 28.04.2008.
4Criminal Court of Cassation Section VI – 9.07.2009 no. 36083.
5 Necessary requirement because the adoption of the model exempts the entity from liability if said model iseffectively implemented.
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6b) the task of supervising the functioning of and compliance with the models as well asof ensuring their update has been entrusted to one of the entity's bodies which has
independent powers of initiative and control;c) the persons who have committed the liable offences have acted in fraudulent
evasion of the aforementioned models;d) the body pursuant to letter b) above did not fail to or insufficiently supervise.
In the event of a crime committed by a person in a subordinate position, the adoption
and effective implementation of the Model means that the entity shall be liable only if
the crime was made possible due to non-compliance with the obligations of direction
and supervision.
Furthermore, the Decree sets forth that the models pursuant to letter a) must satisfy thefollowing requirements:a)identify the activities regarding which it is possible that the offences and crimes
may be committed;b)

set out specific protocols which plan the definition and implementation of theentity's decisions in relation to the crimes and offences;c)

identify financial resource management procedures which are suitable forpreventing committing those crimes and offences;d)

set out information obligations in relation to the body in charge of supervising thefunctioning of and compliance with the model;e)introduce an internal disciplinary system suitable for penalising the failure tocomply with the measures set forth in the model.

Finally, art. 7, paragraph 3 and 4, of the Decree, introduces two principles that appear tobe significant and decisive for the purpose of the entity's exemption from liability, since
it is expressly set forth that:a)the model must set out measures suitable for guaranteeing that business is carriedout in compliance with law, and for discovering at-risk situations in a timely fashion,
taking into consideration the type of business carried out as well as the type andsize of the organisation;b)

for the model to be effectively implemented, routine controls must be carried out
and the model must be amended if significant violations of legal precepts are
discovered or if significant changes are made to the organisation or regulations.

It should be noted that, ultimately, from a merely formal perspective, the adoption andeffective implementation of a model is not required; rather, it is an option for entities.
However, for the companies with shares listed in the Segment of Equities with High
Requirements (S.T.A.R.) of the Telematic Stock Exchange (M.T.A.), organised andmanaged by Borsa Italiana S.p.A. (as are the shares of Datalogic), the adoption and

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7

effective implementation of a model is considered a fundamental prerequisite for alisting in this segment.
1.2 (continues): Liable offences.
Not all offences committed by the parties indicated above involve the administrative
liability of the entity, since the Decree considers only specific types of offences (called
liable offences) relevant. Furthermore, it must be taken into consideration that the"catalogue" of relevant liable offences pursuant to the Decree is being continuously
expanded.
For further details on the liable offences currently in effect, please refer to related
regulatory framework, available on the Gazzetta Ufficiale (www.gazzettaufficiale.it).
However, please note that the Special Parts of this Model only consider the liable
offences for which an appreciable risk level has been detected in relation to the businesscarried out by Datalogic. The Datalogic Board of Directors shall be responsible for addingSpecial Parts in relation to other types of liable offences, if such action is found to benecessary on the basis of routine controls.
1.3 (continues): Penalties.
Should the persons pursuant to the introduction commit one of the liable offences, theentity may be subject to the following administrative penalties:a) financial penalties;b) interdiction penalties, such as:i) the prohibition from carrying on business;ii) the suspension or withdrawal of authorisations, licences or concessions which
may support committing the crime;iii) the prohibition from contracting with the public administration, unless to obtain
public services;iv) the exclusion from facilitations, loans, contributions or subsidies and thepossible withdrawal of those already granted;v) the prohibition from advertising goods and services.
c) confiscation;d) publication of the ruling.
These interdiction penalties may be adopted also as a precaution.
Moreover, the Judicial Authorities may order:
1. the preventive attachment of items permitted to be confiscated;

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82. the conservative attachment of the entity's moveable property and real estate if
there is a grounded reason to believe that the guarantees for the payment offinancial penalties, expenses for the legal proceeding or other amounts due to thegovernment do not exist or are being wasted.
1.4 (continues): Model suitability
For the purpose of drawing up the Model and the subsequent assessment of its
suitability, it should be noted that it is important to take into account the case-law (stillquite scarce) on that issue and the criteria set out thereby; in particular the Court ofCassation (holding an opposite view from the GUP of Milan on 17.11.2009 and the Courtof Appeal of Milan on 21.03.2012) has established, in summary, that “a model isdeemed suitable when the procedures supporting it are suitable to avoid thecommission of a liable offence”.
It is also important to underline what was established by the G.I.P. of Milan (MrD'Arcangelo) in November 2010. The judgement has set out the principle according towhich “acting in compliance with the law is removed from the discretion of thebusinessman, and the non-compliance risk cannot be considered by the Directors as an
acceptable risk”.
This judgement also states that “the judge who is called to decide on the suitability of anorganisational model must refer to the regulations of a certain sector in terms of thetime when the disputed criminal conduct occurred, and must verify which organisational
precautions were adopted by the entity to avoid such criminal act and how the same
were actually implemented with reference to the best technical expertise available at thetime” [...] “the suitable precautionary model is, in fact (as it can be deduced, at amethodological level, also by the mandatory content of art. 30 of Italian Legislative
Decreeno. 81 of 9.4.2008) the one built on the best knowledge, proven and accepted at
the historical moment when the offence was committed, in terms of the methods applied
for neutralising or minimising the typical risk”.
2. GROUP STRUCTURE – Preamble.
Datalogic is a global technology leader in the automatic data capture and factory
automation markets. In particular, the company is specialized in the designing andproduction of barcode readers, mobile computers, sensors for detection, measurement
and safety, RFID, vision and laser marking systems, with the aim to increase theefficiency and quality of processes in the Retail, Manufacturing, Transportation &Logistics and Healthcare industries, along the entire value chain.
The Organisational Structure of the Group encompasses the following companies,
included in the scope of application of Italian Legislative Decree no. 231/2001, directly
or indirectly controlled by Datalogic S.p.A.:➢ Datalogic S.r.l.;➢ Datasensing S.r.l.;➢ Datalogic IP TECH S.r.l..

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92.1 (continues): Datalogic S.r.l.
The company Datalogic S.r.l. carries out research, design, manufacturing (also underlicense agreements), marketing, sale and distribution (including related installation,
repair and maintenance services) of the products - services of the Datalogic Group, andin particular:➢ Electronic equipment, software and systems for the reading, recognition,acquisition, collection, processing, monitoring, control, transmission andcommunication of data and voice of any type, including devices (fixed and/or
portable) for the scanning of bar codes (and/or other symbols) and mobile
computers for the collection, processing and transmission of data and voice, fixedscanning systems for reading bar codes and/or other symbols for any type of
application that allows for the generation, collection, processing and transfer ofdata;➢ Data reading, writing and transmission with RFID (Radio Frequency Identification)technology or other technologies;➢ Laser-based technology systems for the marking, cleaning and/or welding ofproducts, and for applications in the medical and safety fields;➢ Sensors for identification, measurement and safety;➢ Vision systems;➢ Image-based identification systems;➢ Control, management and configuration of equipment network systems andsoftware;➢ Software for the management of points of sale.
Datalogic S.r.l. uses different R&D centres (located in different countries such as Italy,
the US and China) as well as different production sites (located in Italy, Slovakia,
Vietnam and Bulgaria) operating in more than 30 countries through its own subsidiaries
and/or companies (Europe, America, Asia and Oceania).
2.2 (continues): Datasensing S.r.l.
The company Datasensing S.r.l. carries out research, design, manufacturing, marketing,sale and distribution of the products - services of the Datalogic Group, and in particular:➢ Vision and image-based identification systems;➢ Sensors for identification and measurement and safety;➢ Optical and laser sensors for applications in safety fields.

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10Datasensing S.r.l. uses an R&D centre as well as different production sites (located in
Italy and China) operating in different countries through its own subsidiaries and/or
companies.
2.3 (continues): Datalogic IP TECH S.r.l.
The company IP TECH S.r.l. carries out activities for the development, coordination andorganisation of advanced research works within the Datalogic Group, through:➢ the use and exploitation, in all forms, of the results obtained from the research;➢ acquisition of and making available technologies and know-how as well as the
management of technological products;➢ management, in all forms, of the activities related to the protection of patents,
licenses, know-how and other intellectual and industrial property rights.
2.4 (continued): Datalogic Group and administrative liability as per Italian Legislative
Decree 231/2001
As the Holding company of the Group, Datalogic S.p.A., in order to further improve theapplication of the provisions of the Decree, has deemed it appropriate to adopt, withthis Model, a “231 System” which would represent, through its principles, the reference
point for the other companies that are part of the Group. The system can besummarised as follows:
1. all the Italian companies that are part of the Datalogic Group, directly or indirectly
controlled, have adopted, autonomously and depending on their own characteristics
and structure, as well as of their risk profile, an Organisational Model;
2. this Model, once adopted, is subject to appropriate implementation for the mosteffective execution;
3. for each company, a Supervisory Body is appointed, in compliance with theprovisions of the Decree in terms of composition, expertise and functions;
4. Datalogic S.p.A. sets out, for its own protection, the minimum criteria of theOrganisational Model adopted by the several subsidiaries, as well as the operational
criteria of the different Supervisory Bodies;5. The Supervisory Body of Datalogic S.p.A., among its specific tasks, must monitor toensure, through appropriate information flows, that all the Supervisory Bodies of
the Group correctly carry out their control activities, as set forth in the Decree.
3. CORPORATE GOVERNANCE - Datalogic S.p.A.
Datalogic continuously places particular focus on the effectiveness and implementationof its corporate governance system, and uses corporate governance domestic andinternational best practices as a basis for a further development of its decision-making
and control structures.

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11Datalogic S.p.A. traditional corporate governance system, shown in the flowchart below,
is inspired by the principles of management and informational fairness andtransparency, which it achieves through a process that continuously controls theeffective implementation and effectiveness of those principles.
In compliance with the unique features and characteristics of its corporate structure,
Datalogic complies with the Code of Conduct in the forms and in compliance with theconditions set forth in its Report on Corporate Governance and Ownership Structure,drawn up pursuant to article 123-bis of the TUF, which may be found atwww.datalogic.comin the Governance section. The content of this report is an integral
and essential part of the Model.

4. THE DATALOGIC MODEL – Preamble.
Datalogic decided to adopt and implement the Model with the conviction that it could
be a valid instrument for raising awareness in all parties that work in the name and on
behalf of Datalogic, so that they behave correctly and consistently while carrying out
their tasks in order to prevent the risk of committing crimes and offences.
The Datalogic Model - representing a “deed issued by the executive body” (pursuant toart. 6, paragraph 1, letter a) of the Decree) - was approved for the first time by the
Board of Directors of the Company on 12 May 2005, and was subsequently fully adopted
by the administrative bodies which, over time, have succeeded the previous ones andhave made, at the request of the Supervisory Body, a range of additions to the Model inaccordance, on the one hand, with the evolution of the organisational structure of thecompanies and, on the other hand, with any new provisions applicable to this area over

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12the years through the introduction of additional types of liability offences6.
The Organisational Model of the Company, drawn up also in compliance with theConfindustria “Guidelines”, is based on a pyramid structure of principles and proceduresthat can be described as follows:a) A General Part, where the Model is described in terms of objectives, functioning andcorporate bodies in control thereof;b) A Special Part, where all the operating processes, aimed at preventing thecommission of offences within the corporate scope, are defined, in particular:i.

Crimes against the public administration;ii.

Corporate crimes;iii.

Market abuse;iv.

Occupational safety;v.

Receiving stolen goods and money laundering;vi.

Cybercrimes and unlawful data processing;vii.

Tax crimes.

For the definition of the Special Part “Safety at the workplace”, the OHSAS 18001:2007
international standards have been adopted as a reference point for the parts regarding
safety and hygiene at the workplace.

6 The Board of Directors carries out the following activities in order to adopt and routinely update theModel:
a)
b)

c)
d)

identifying the corporate operating areas to be included in the Model and mapping the atrisk activities to subject to analysis and monitoring;
analysing existing protocols on at-risk activities and defining any implementations aimed atensuring compliance with the precepts of the Decree; in that area, particular attention ispaid to:(i)the definition of ethics principles in relation to the behaviours that could amountto the crimes and/or offences;(ii)
the definition of Datalogic processes which, in principle, could provide theconditions, occasions or means for committing crimes and/or offences;(iii)
the definition of employee training procedures;(iv)
the definition of information to be provided to Addressees;(v)
the definition and application of disciplinary provisions which are suitable forpenalising lack of compliance with the measures set forth in the Model and aresuitable for deterring the commission of crimes;
the identification of the Supervisory body and attributing specific tasks to it aimed at
supervising the effective and correct functioning of the Model;
the definition of information flows to the Supervisory Body.

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4.1 (continues): Role of the Model.
The Model is based on a structured and organised system of procedures and control
activities (to be carried out also preventively), implemented by Datalogic and aimed atpreventing the commission of crimes and offences.
In particular, through the identification of at risk activities, as well as of the control
measures to which said activities are subject, the Model intends to:a) develop awareness in all parties that work in the name and on behalf of Datalogic,
especially in those at-risk activities, that if they violate the provisions set forth in the
Model, they are committing a crime subject to penalties on both the criminal andadministrative levels, which will be charged not only against that party, but also
against Datalogic;b) remind the addressees that Datalogic strongly condemns those unlawful behaviours
since (even if Datalogic were apparently in the condition to reap advantages fromthem) they are in any case against both legal provisions and the ethical-corporate
principles that the company adheres to in executing its corporate mission;c) permit Datalogic to react in a timely manner to prevent or impede the commissionof crimes and offences by making use of a system to monitor at-risk activities.
Datalogic has identified the following specific tools that are employed to plan thedefinition and implementation of company decisions and execute controls on corporate
activities, also in relation to the crimes and offences to be prevented:
1. the rules of corporate governance adopted in transposing the Code of Conduct;
2. the Code of Ethics;
3. the internal audit system;
4. the penalty system referred to in the National Collective Labour Agreements.

4.2 (continues): Mapping of at-risk activities.
Through an analysis of the operating structure of Datalogic, the main at risk activities, aswell as the related corporate areas7 and protocols adopted as preventive measures,
have been identified. The results of this analysis are summarised in the table below.

7

The functional aggregation of the At-Risk Areas - Activities is representative of the current Organizational
Design – Operational Footprint of the Group (available on the website www.datalogic.com – Organization
section).
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Corporate areas at risk

Specialparts

At-risk activities

A

Crimes against the
Public Administration

B

C

D

E

F

G

Corporate Crimes

Market Abuse

Safety in the workplace

Handling stolen goods
and money laundering

Cybercrimes andunlawful dataprocessing

Tax crimes

AFC

LEG
& IP

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

IT

✓

✓

✓

✓

✓

✓

RU

SG

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

OP

✓

✓

✓

✓

✓

✓

Preventive protocols
COM

✓

✓

✓

✓

✓

✓

Risk Assessment Highlights
Main preventive protocols(related to main activities)

ST

ORG

PROC

SIS

Main At-risk activities

✓

✓

✓

✓

> Administrative measures
instrumental to the performance ofcorporate activities (authorizations certifications)> Governance: AFC – SG – LEG & IP
> Processes: vendor selection – indirect procurement– payment management> Systems: accounting – information> Representation of corporate eventsin the Financial Statements> Governance: AFC – LEG & IP
> Processes: financial reporting> Systems: accounting – information> Certifications: accounting – financial> Extraordinary transactions> Governance: AFC – LEG & IP
> Processes: inside information – extraordinarytransactions> Systems: accounting – information> Certifications: accounting – financial> Inside information - extraordinarytransactions> Governance: Company Direction – AFC – LEG & IP
> Processes: inside information – internal dealing> Systems: accounting – information> Certifications: accounting – financial> Public reporting> Governance: AFC – LEG & IP – COM> Processes: corporate events management – external
communication> Systems: accounting – information> Certifications: accounting – financial> Facility Management> Governance: SG – RU – LEG & IP
> Processes: safety safeguards management> Systems: accounting – information> Certifications: ISO 45001 – ISO 14001 – SA8000> Commercial Transactions> Governance: OP – VM – AFC – LEG & IP
> Processes: procurement – payment – sales –revenues> Systems: accounting – information> Certifications: accounting – financial> Financial Transactions> Governance: AFC – LEG & IP
> Processes: financial management> Systems: accounting – information> Certifications: accounting – financial> IT security – internal infrastructure> Governance: IT – LEG & IP
> Processes: IT security management (software –hardware)> Systems: accounting – information> Certifications: ISO 27001> IT security – products and solutions> Governance: RS – IT – LEG & IP
> Processes: IT security management (products –solutions)> Systems: accounting – information> Certifications: ISO 27001> Tax declarations> Governance: AFC> Processes: tax calculation – ICTP model> Systems: accounting – information> Certifications: accounting – financial> Tax credits> Governance: AFC – RS – LEG & IP
> Processes: calculation of patent box credits –product and solutions development> Systems: accounting – information> Certifications: accounting – financial

✓

✓

✓

✓

✓

✓

Corporate areas at risk:
AFC Administration, finance and control
LEG & IPLegal affairs and intellectual property
IT
Computer systems
RU
Human resources
SG
General services
OP
Purchasing, planning, production, logistics, quality, engineering (Operations)
VM
Communication
ST
Strategy

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

✓

Preventive protocols:
ORG Organizational structure / System of proxies / Separation of roles
PROC Corporate procedures and processes / Codes of conduct / Operational frameworks
SIS Information and application systems / IT infrastructure

The following preventive protocols guarantee the prevention of offences and/or crimes
as well as the monitoring of the corporate areas at risk:
ORG: general configuration of the corporate organizational structure and consequentassignment of powers and responsibilities; segregation of duties aimed at avoiding
overlapping or centralization of approval powers;
PROC: existence of corporate procedures and processes that guarantee the protectionof company assets, the efficiency and effectiveness of company operations, thereliability of the accounting and financial information and compliance with laws andregulations; adoption of codes governing suitable rules of conduct to guarantee theexercise of business activities;
SIS: presence of an IT system to guarantee the process to prepare accounting andfinancial reports, as well as to oversee reliability – fairness of information and activities,
conveyed through the use of applications and, more in general, of the corporate IT
infrastructure.
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A Special Part is dedicated to these at risk activities to which reference should be made.
The risk associated with other liable offences8, as set forth in the Decree, is actuallyquite remote and difficult to conceive in the interest or advantage of Datalogic.
4.3 (continues): Control principles and preventive control systems.
The Model is based on the internal control system of Datalogic, founded on theattribution of responsibilities, hierarchical structure lines and description of tasks, with a
specific set out of control principles, such as, for example a system of checks andbalances.
In particular, the manual and electronic procedures implemented by Datalogic (themanagement computer system and in general the processes managed by the
Information Systems function) are such as to regulate the carrying out of activities whilesetting up the appropriate control points and adequate security levels.
In addition, in designing the processes, where ever possible, a separation of tasks wasintroduced for those who carry out crucial activities within a process at risk, andtransparency and auditability principles were taken into consideration (in particular, it
was ensured that each operation, transaction, action would be verifiable, documented,
consistent and appropriate).
As regards financial management where the procedural controls use validated tools,
different preventive protocols were adopted including joint signature (for amounts
exceeding the strict needs of daily operations), frequent reconciliations, supervision andlevels of authorisation, separation of responsibilities with the above mentioned systemof checks and balances.
The model also provides for a management control system capable of providing timely
alerts, as the case may be, regarding the onset or the existence of abnormal situations.
Within the organisational system, specific attention was paid to the system of bonuses
that are meant to be incentives but are also achievable, thus avoiding objectives that are
obviously unreasonable and unreachable which then might lead to the commission of
offences and/or crimes.
In addition, with a special reference to authorisation and signature powers, these havebeen assigned based on the defined organisational and management responsibilities,
thus establishing in advance, when necessary, a precise indication of the thresholds for
expense approval.
The limits in authorisation and signature powers are transposed, as blocking protocols,
into the general information system.
In all cases, depending on the current Model, nobody is attributed unlimited powers andappropriate measures are adopted so that powers and responsibilities are clearly
defined and well known inside the organisation.
8

For the complete list of offenses, please refer to the full text of Italian Legislative Decree 231/2001, andsubsequent amendments and additions.
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To this end, no one can manage in total autonomy an entire process, and for eachtransaction an adequate documentation support (or electronic support for processes
under the management information system) is required and can be, at times, audited toverify the characteristics of and motivation for a specific transaction as well as to
identify the subjects who have authorised, recorded or verified said transaction.9
Therefore, the Model covers all aspects of Datalogic activities also through a clear
distinction between the operating tasks and the control tasks, for the purpose ofcorrectly managing activities at risk and avoiding possible conflict of interest situations.
In particular the controls involve, with different roles and at different levels, the Boardof Directors (in particular the Control and Risk Committee established within it), theBoard of Statutory Auditors, the subject in charge of internal controls (Internal
auditor)10, the Supervisory Body and the Employees.
As regards the aspects of “controls”, the Model, besides providing for the establishmentof an autonomous and independent Supervisory Body, guarantees the integration andcoordination of the activities carried out by the latter with the existing system forinternal control, building on the accrued expertise.
The Model does not modify the functions, the tasks and the objectives already existingin the control system, but aims at providing greater guarantees about compliance of thecorporate practices and activities with the provisions of the Code of Ethics and thecorporate regulations which set forth the principles that govern the at-riskactivities.
Finally, still in the areas of controls, the Models provides for the obligation of
documenting (also through the drawing up of reports) any inspection and control
activity that is carried out.
5. MODEL AND CODE OF ETHICS
The conduct rules in this Model are complementary to those in the Code of Ethics,
although, due to the ends that the Model intends to pursue in the implementation of
the provisions set forth in the Decree, its scope is different from that of the Code of
Ethics.
In fact, while the Code of Ethics is an instrument adopted independently, and isgenerally applied by Datalogic in order to express the principles of "corporate ethics"
that the Datalogic Group recognises as its own and with which all employees are called

9The Model aims at guaranteeing the principle of separation of functions, so that the authorisation forcarrying out a transaction must be under the responsibility of a person different from the one in charge ofthe accounting, or the one who is operatively executing or controlling the transaction.
10It must be noted that on 26 June 2007, the Board of Directors of Datalogic approved the regulations issued
by the Audit Committee aimed at governing, in a uniform and coordinated fashion, the tasks and theaccounting control functions of the Special Accounting Committee, called Audit Committee. Morespecifically, the Audit Committee ensures the monitoring and the control of the organisation and ensuresthe efficiency of the internal control procedures and processes for the preparation of the financial
statements, while also guaranteeing the uniformity, comparison and coordination of the activities carriedout by the existing control bodies (such as the Control and Risk Committee, the Board of Statutory Auditors
and the Independent Auditing firm). Currently the Audit Committee has been established at Datalogic S.r.l.
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to comply, the Model, on the other hand, satisfies specific precepts contained in the
Decree and in the TUF, aimed at preventing the commission of crimes and offences.
6. THE SUPERVISORY BODY – Preamble.
As a condition for obtaining exemption from administrative liability, art. 6, lett. b) of theDecree requires that the task of supervising the functioning of and compliance with theModel as well as its relative updating be entrusted to a body within the company that
has independent powers of initiative and control.
The Board of Directors, considering the size of the Company, its organisational structure
and the characteristics of its business, establishes the Supervisory Body by appointing its
members after determining the number, in compliance with the requirements stated inthis paragraph, or attributing the related functions to the Board of Statutory Auditors
appointed by the Shareholders' Meeting.
The Supervisory Body is characterised by the following requirements:-

Autonomy and independence
The requirements of autonomy and independence are fundamental in ensuringthat the Supervisory Body is not directly involved in the management activities
that constitute the subject matter of its control activities. These requirements
are guaranteed by the indisputability, by the corporate bodies, of the decisions
made by the Supervisory Body and provide for the obligation of reporting to theBoard of Directors.

-

Professionalism
The Supervisory Body has, internally, the technical-professional skills andexpertise adequate to the functions that it is called upon to carry out; thesecharacteristics, together with its independence, guarantee the objectivity of its
judgement.

-

Business continuity
The Supervisory Body (i) works constantly on the supervision of the Model,
vested with the necessary auditing powers; (ii) it is configured as an internal
structure, so as to guarantee the continuity of its supervisory activity; (iii) it
ensures the implementation of the Model and its constant update; (iv) it does
not carry out operating tasks that may affect its overall corporate vision of theactivities performed.

The tasks assigned to the Supervisory Body require, therefore, that, in carrying out its
activities: (i) it holds autonomous powers of initiative and control; (ii) it is placed outsideof the production processes, as a staff unit reporting directly and exclusively to theBoard of Directors and therefore is not bound by any hierarchical relationship with theindividual managers of the corporate operating structures.
In carrying out its supervisory and control activities, the Datalogic Supervisory Body (i) is
supported by all the corporate functions and may use other external resources, if
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necessary, from time to time; (ii) is authorised to freely access all the Company's
functions – without any prior consent – in order to obtain information or data that it
deems necessary to carry out the tasks as set forth in Italian Legislative Decree
231/2001.
It must be noted that as regards health and safety, the Supervisory Body may use all the
resources available for the management of related aspects, including the Manager of
the Prevention and Protection Service (Responsabile del Servizio di Prevenzione e
Protezione - RSPP), the staff of the Prevention and Protection Service (Addetti al Servizio
Prevenzione e Protezione - ASPP), the Workers Safety Representative (Rappresentantedei Lavoratori per la Sicurezza - RLS) and the Occupational Physician (Medico
competente - MC) as well as the staff in charge of providing first aid and managing any
fire emergency situations.

6.1 (continues): The composition of Datalogic’s Supervisory Body.
The Board of Directors, if the functions of the Supervisory Committee are not attributed
to the Board of Statutory Auditors, may freely choose the members of the Body itself
from among those subjects who meet the following:-

Professional requirements
The members of the Supervisory Body must be chosen from among thosesubjects who are specifically qualified and with experience in administrative orcontrol activities, or subjects who have held executive positions in companies,
public entities, public administration or who have carried out or are carrying out
professional or university teaching activities in judicial, economic and financial
subject matters.
In consideration of the size and related rules of corporate governance, thepresence in the Supervisory Body of the following is recommended:a. the manager of the Internal Auditing office of Datalogic who must be
knowledgeable of the organisational and corporate structures and be
therefore able to facilitate the actual and concrete activities to be carriedout by the Supervisory Body, as set forth in the Decree;b. two professionals, lawyers or economists, who have accrued specificexpertise in the criminal law applied to the economy, finance andcorporations, so as to consistently support the activities of the Supervisory
Body with a “legal sensitivity” that is clearly “specialised”11.

- Personal and integrity requirements

11

For biographical and background information on the members of the Supervisory Body in office, see the
Corporate Governance and Shareholding Structure Report, pursuant to art. 123-bis of TUF, to be consulted
on the web site www.datalogic.com- section Governance.
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It is also necessary to guarantee that the members of the Supervisory Body
have, in addition to professional qualifications, also personal qualities such as
the ability to carry out the tasks assigned to them which they must declare at
the time of their acceptance of the appointment. The members of theSupervisory Body must be free from any incompatibilities and conflicts ofinterest that may affect their independence and freedom of action andjudgement.
Those who do not meet the requirements of integrity set forth for the membersof the Board of Directors, pursuant to art. 147-quinquies of TUF, as well as unfit,
disqualified and incapacitated subjects may not be appointed as members of theSupervisory Body.
At the time of their appointment, the members of the Supervisory Body must issue a
specific declaration stating that they meet the set forth requirements and that they
undertake to inform the Company in case their eligibility should change in the course of
their mandate. The Supervisory Body members shall be appointed by the Board of
Directors and generally remain in office until the expiry of the mandate set for that
Board of Directors by the shareholders' meeting, or for the entire period established by
the Board of Directors at the time of the appointment.
The Board of Directors provides the Supervisory Body with the financial resources
necessary to fulfil its duties.
The functions and powers of the Supervisory Body (identical for all Special Parts) as wellas the procedures for managing the necessary information flows are summarised in theparagraphs below.
6.2 (continues): Roles and powers of Datalogic's Supervisory Body.
The Supervisory Body is responsible for supervising:a)Addressees' compliance with the Model;b)the effectiveness and adequacy of the Model with respect to the corporate
structure and its effective ability to prevent the commission of crimes and/or
offences;c)the opportunity to update the Model, if the prerequisites are met, by formulating
proposals to the Board of Directors as a consequence of: (i) significant violationsof the provisions of the Model, (ii) significant changes in the internal structure of
the Company and/or the methods for carrying out company activities, (iii)
legislative amendments to Italian Legislative Decree 231/2001 or amendmentsthat hypothesise new direct liabilities of the entity;

In addition, the Supervisory Body, following the assessment of infringements of theOrganisational Model, is required to timely report such violations to the Human
Resources Dept. and in case of the objective gravity of the infringements involving a
disciplinary action (also in consideration of the role held by the subject who committed
the infringement) to the Board of Directors and to the Board of Statutory Auditors forthe necessary disciplinary actions to be taken.
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The above tasks are completed through the execution of the following activities:(i)

preventive inspections and controls on at-risk activities, using specific check lists, oron the effectiveness of company processes and filing of the related documentation;(ii) Interviews with top managers of Datalogic, holding the main responsibilities for theactivities at risk;(iii) employee training and addressee information disclosure;(iv) updating and maintenance of the Model in relation to changing corporate and/or
regulatory conditions;(v) analysis of reports received regarding each violation or suspected violation of theCode of Ethics and/or any other preventive protocol envisaged by the Model.
The Supervisory Body makes use of information flows obtained from the managers ofeach business area, as well of Internal Audit, as Datalogic's head of internal control. The
activities carried out and the tools utilised allow for detecting any exceptions andanomalies as well as implementing the necessary corrective actions.
The Supervisory Body formally meets at least once every quarter, except for in
emergency situations. Minutes on each meeting must be drawn up in the previously
authenticated register of Supervisory Body meetings. The minutes of each meeting shallbe signed by all Supervisory Body members in attendance.
6.3 (continues): reporting of Datalogic's Supervisory Body.
The following procedures are used to report on the Supervisory Body's activities:a)half-yearly, to the Datalogic Audit and Risk Committee and the Board of Statutory
Auditors;b)annually, to the Board of Directors in a report containing results achieved during
the year and the action plan for the subsequent year.

The Board of Directors and Board of Statutory Auditors may call a meeting of theSupervisory Body at any time, and the latter in turn has the right to request, through theapplicable functions and parties, that the aforementioned bodies meet for urgent
reasons.
7. INFORMATION FLOWS TO EMPLOYEES
Since Datalogic is aware that training and information disclosure are part of a preventive
protocol of utmost importance, it works to ensure that employees are familiar with thecontent of the Decree and the obligations generated thereby and the Model.
The activities related to training, awareness raising and information flow for the
Employees, as well as for all Corporate Bodies, are managed by the heads of thecorporate functions involved in the application of the Model in cooperation with the

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21Supervisory Body, starting from the hiring time or the beginning of the employment
relationship.
The following activities should be noted:a)delivery, to the newly hired employees, of an information set (in addition to thematerials indicated by other policies or corporate procedures, such as privacy andprotection of personal information, hygiene and safety at the work place); theNational Collective Labour Agreement; a summary of the contents of the Decree
and the Model, with which to ensure that they acquire the knowledge that is
considered relevant;b)

employees must sign a dedicated form indicating acknowledgement andacceptance;c)specific training is provided either in classroom courses or through e-learning tools
and services (in that case, with a solution whereby it may be verified that thetraining took place).

There is a specific area of the corporate IT network dedicated to the Decree, which also
guarantees that employees are trained and are knowledgeable.
8. INFORMATION FLOWS TO THIRD PARTIESThe corporate functions that have institutional contact with other Addressees, namely
Partners, Suppliers and Consultants, shall provide them with dedicated informational
documents, in coordination with the Supervisory Body, on Datalogic's policies andprocedures based on the Model and the Code of Ethics as well as on the consequencesthat behaviours contrary to the expectations of the Model or in any case contrary to theCode of Ethics or current regulations may have on contractual relations.
When possible, the contractual terms shall contain specific clauses aimed at enforcing
those consequences, such as termination clauses or rights to withdraw in the event of
behaviours contrary to the standards of the Code of Ethics and/or protocols of theModel.
9. DISCIPLINARY SYSTEM - Preamble.
A system of penalties proportional to the violation of preventive protocols and/or
additional rules of the Model or the Code of Ethics is necessary in order to guaranteethat the Model is effective and that the Supervisory Body can act efficiently. In fact, in
accordance with art. 6, paragraph 1, letter e) of the Decree, this disciplinary system is an
essential requirement for Datalogic's exemption from liability.
The disciplinary system of Datalogic provides for penalties applicable to any Addressee,
depending on the type of relationships and in compliance with the principles of
proportion and litigation, due to which the penalty applied is always commensurate to
the gravity of the disputed act, thus guaranteeing to the involved subject the possibility
to justify and defend his/her own behaviour.

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The application of the disciplinary system and related penalties is separate from thepossible establishment of criminal proceedings and the resulting judgement for an
unlawful behaviour covered by Italian Legislative Decree 231/2001. The main objectiveof the disciplinary system of Datalogic, by completing the Model and making it effective,
is in fact not so much the repression of offences once they have been committed, butrather the avoidance of the behaviours that typically precede the commission of
offences and consequently avoiding the materialisation of such offences, except for
fraudulently circumventing the Model itself.
The disciplinary system of Datalogic plays therefore an essentially preventive role andacts as an additional internal control for preventing the application of “external”
penalties imposed by the Court.
The disciplinary system of Datalogic is constantly monitored by the Supervisory Body
and by the Human Resources Dept.
As regards the assessment of infringements, the disciplinary procedures and theapplication of penalties are under the responsibility of Human Resources,
notwithstanding the necessary involvement of the Supervisory Body in the proceduresfor the assessment of the infringements and the application of penalties for infringing
the Model. Therefore, the storage of a disciplinary provision, or the application of adisciplinary penalty for infringement of the Model, needs the preventive information toand opinion from the Supervisory Body.
It is therefore the right of the Company to have recourse for the damages and/or
liabilities deriving to it from the conduct of the employee in violation of the Model.
In order to preventively specify the criteria correlating the workers’ offences and thedisciplinary measures adopted, the Board of Directors classifies the actions undertaken
by Directors, Auditors, Employees and third parties into:
1. behaviours which show that orders imparted in both in written and verbal form byDatalogic were not followed while carrying out at-risk activities, such as, but notlimited to:➢ violation of procedures, regulations, or internal written or verbal instructions;➢ negligently violating, avoiding or disabling one or more preventive protocols;
2. behaviours which show that a serious infraction of workplace regulations and/or
diligence has occurred, causing the Company to completely lose faith in the Director
and/or Employee, such as:
3. adoption, while carrying out activities at risk, of behaviours under previous point 1
unequivocally aiming at the commission of an crime and/or offence or offences
appearing as damaging to Datalogic; behaviours which cause serious moral ormaterial damage to Datalogic, such that the relationship cannot be continued, eventemporarily; for example acting in a way which constitutes one or more offences
and/or unlawful behaviour, or behaviours, under previous point 1, carried out with
the intent to cause damage.

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4. conduct that prevents or affects the use of communication channels dedicated toreporting any violations of the Model (so-called Whistleblowing), such as:➢ failure to establish reporting channels;➢ failure to establish procedures for making and handling whistleblowing;➢ adoption of procedures for the execution and management of reports that do
not comply with the provisions of the law;
➢ implementation of acts, or behaviors, retaliatory, or impediments, to the releaseof the whistleblowing.
The Supervisory Body is continuously monitoring the suitability of the disciplinary
system in relation to the precepts of the Decree.
9.1 (continues): Employee penalties.
For employees, the limitations related to disciplinary powers imposed by article 7 of
Italian Law no. 300/1970 (called the "Statute of workers' rights") and by National
Collective Labour Agreements must be respected, both as regards applicable penalties(which are generally classified based on the connection with undue disciplinary
specifications) and as regards the form and exercise of that power.
The disciplinary system currently applied by Datalogic is in line with the provisions of the
National Collective Labour Agreements and complies with the requirements ofeffectiveness and deterrence.
An employee's failure to respect and/or violation of the general principles of the Model,of the conduct rules imposed by the Code of Ethics and of corporate procedures,
regulations or instructions is therefore breach of the obligations imposed by theemployment relationship and a regulatory offence (such as insubordination, negligent
execution of services, or detriment to company regulations or morals, in accordancewith article 24 of the National Collective Labour Agreement, letters c), d) and i);
infractions of the regulations and/or diligence of the employment relationship more
serious than those pursuant to article 24, in accordance with article 25, letters A) andB)).
The applicable penalties shall be adopted and applied with full respect for theprocedures set forth by national collective labour regulations applicable to that
employment relationship.
Without prejudice to the principle of the link between the applicable disciplinary
measures and the cases in which these measures may be implemented, the principle ofproportionality between the infraction and the penalty must be respected when
applying the disciplinary penalty. There is no prejudice, and reference is hereby made, toall the provisions under above mentioned art. 7 of the Italian law 300/1970 concerning
both the exposure of the disciplinary codes “through the display in a place accessible toall” and the obligation of a preventive notification of the charge to the employee, also inorder to allow said employee to acquire an appropriate defence and provide anynecessary justification.
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INTERNAL Datalogic Confidential249.2 (continues): Manager penalties.
If managers violate the general principles of the Model, the conduct rules imposed by
the Code of Ethics and the other preventive protocols, Datalogic shall apply themeasures deemed suitable for those managers on the basis of the seriousness andsignificance of the violations committed, also in consideration of the particular trust
existing in the relationship between Datalogic and the employee in the role of manager.
In the cases pursuant to point 2. of the introduction, Datalogic may terminate the work
contract in advance or apply another penalty deemed suitable in relation to theseriousness of the case. If the manager's behaviour exemplifies the cases set forth inpoint 3. of the introduction, Datalogic shall enact the advance termination of the work
contract without prior notice pursuant to article 2119 of the Italian Civil Code and article
23, paragraph 1, point 1. of the National Collective Labour Agreement. This is because
the deed must be deemed to have been implemented against the will of Datalogic in theinterest or to the advantage of the manager and/or third parties.
9.3 (continues): Penalties for the Board Directors and the Board Auditors.
If a Datalogic director or auditor commits crimes and/or offences or violates the Code of
Ethics, the Model and/or the relative preventive protocols, the Supervisory Body shallinform the entire Board of Directors and the Board of Statutory Auditors, which areresponsible for taking suitable action.
In cases of serious violations by the Directors which are unjustified and/or not
authorised by the Board of Directors, the deed may be considered just cause for the
revocation of the office. Behaviours constituting the crimes and/or offences are
considered a serious, unjustified violation.
9.4 (continues): Third party measures.
Except for exceptional situations to be brought to the attention of the Supervisory Body,
any type of contract, including supply, outsourcing, agency, commercial agency,
business agent, joint venture and consulting contracts, may not be considered validly
executed with Datalogic unless the contractor commits to respecting the Code of Ethics
and/or the applicable preventive protocols.
These contracts must include termination clauses or rights to withdraw in favour of
Datalogic, which shall bear no penalty, if crimes and/or offences are committed, or if
rules of the Code of Ethics, the Model and/or the relative preventive protocols are
violated.
In any case, Datalogic reserves the right to possibly request indemnification if it
undergoes damages as a result of that behaviour, for example if the judge applies
measures sets forth by the Decree to Datalogic.

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10. REPORTING
Each recipient of the Model has the right to report any violations to the Company, evenanonymously, through the following communication channels:
Whistleblowing Platform available on the Company’s website(https://datalogic.integrity.complylog.com/), which guarantees the possibility of
issuing written whistleblowing reports or through the recording of voicemessages.
Thus, through a face-to-face meeting with the Company's Supervisory Body.
Each whistleblowing is taken over and assessed by the Company according to thecorresponding provisions of the law12, in the relative ways and times, providing:➢ acknowledgment of receipt of the report, within 7 days of the same;➢ formal response, within 3 months of acknowledgment of receipt;➢ consequent document archiving.
In order to ensure an adequate assessment, the contents of the whistleblowing arecharacterized as:➢ based upon facts that are objective, detailed and consistent, as well as free ofany personal opinion;➢ free of any opportunistic, disparaging, improper or instrumental purpose;➢ aimed at protecting the integrity of the Company.
Finally, please note that the Company guarantees adequate protection to thewhistleblower from any retaliation and prejudicial consequences, not revealing his
identity, without prejudice to legal obligations.

*** OMISSIS ***12

Legislative Decree 231/2001 as amended, EU Regulation 2016/679 on Privacy and in the EU Directive
2019/1937 on reporting (so-called "Whistleblowing").
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