CORPORATE PROCEDURE P&O 007
Diversity, Equity & Inclusion

Company: OTB Group
Issued by: People & Organization OTBApproved by: Governance Committee
Type: Corporate Procedure
Effective as from: September 2023
Recipients: OTB Group employees

Version No.: 01

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TABLE OF CONTENTS

1.

FOREWORD ................................................................................. 3

1.1 RECIPIENTS AND RELEVANT STANDARDS ................................ 3
2.

COMMITMENT OF THE OTB GROUP ......................................... 33.

KEY PRINCIPLES FOR THE OTB GROUP ................................. 44.

OBJECTIVES OF THE OTB GROUP ........................................... 55.

IMPLEMENTATION ...................................................................... 66.

COMMUNICATION AND DISSEMINATION ................................. 6

7.

MONITORING AND REVIEW ....................................................... 7

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1. FOREWORD
This Diversity, Equity & Inclusion Policy (hereinafter also 'the Policy') definedby the OTB Group's Top Management in collaboration with the Diversity,
Equity & Inclusion Committee (hereinafter also 'DEI Committee' or'Committee'), sets out the principles, objectives, guidelines that define theGroup's commitment to enhancing Diversity, Equity and Inclusion.

1.1 RECIPIENTS AND RELEVANT STANDARDSThis Policy applies to the Group's internal staff as well as to external staff
collaborating therewith on an ongoing basis.
The relevant external standards on which this Policy is based are:

-UNI/PdR 125:2022 Practice

The relevant internal documents for this Policy are:-Code of Ethics;-Diversity, Equity & Inclusion Plan;-

DEI Committee Regulations;-HR Policy for Gender Equality.

2. COMMITMENT OF THE OTB GROUPThe OTB Group (hereinafter also 'the Group') has always been actively
committed to promoting and respecting the principles of Diversity, Equity andInclusion with respect to all its staff and anyone working in the name and/or
on behalf and/or in the interest of the same, or anyone having business
relations or collaborating therewith in any other way.

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Diversity, Equity and Inclusion are at the heart of the values of the OTBGroup: they are essential levers to ensure the Group's success and to makeits people capable of reflecting, understanding and enhancing the diversity ofthe customers they serve, to promote well-being and social progress, and toensure a fair working environment.
The OTB Group has thus embarked on a path made up of great commitment
and concrete actions to eliminate all forms of direct or indirect discrimination
and any cultural, organisational or material barrier that may limit individuals'
full expression and their full enhancement within the organization.

3. KEY PRINCIPLES FOR THE OTB GROUPThe OTB Group pays particular attention to people. Therefore, it promotes
messages, actions and behaviours that create a sense of belonging and aworking environment in which everyone can feel welcome, free to fully
express their identity, ideas and skills.
Hence, the principles of Diversity, Equity and Inclusion are fundamental in themanagement of the Group's activities; these principles represent the ethicalstandard for all Group companies and are specified as follows:1.

Diversity: 'diversity' means observing and promoting the personal

uniqueness and differences (in terms of nationality, ethnicity, sexual
orientation, gender, physical, cognitive or any other abilities or health status)of all individuals in a society.
Equity: 'equity' means guaranteeing equal opportunities and justice throughpolicies and processes that enable everyone to have the right conditions tocontribute effectively to company life. Inclusion: 'inclusion' means creating acontext that promotes culture and conducts through which everyone can feel
welcome, safe and free to express themselves.

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4. OBJECTIVES OF THE OTB GROUP
All diversity characteristics are equally important for the Group, which
therefore promotes their respect and enhancement within its businesspractices so as to develop an inclusive culture, identifying them as follows:●gender;●age;●disability;●

sexual orientation;●religion;●nationality.

The OTB Group has also identified the issues (as indicated in the UNI/PdR
125:2022 Practice) for which gender equality objectives have been defined,detailed in the Diversity, Equity & Inclusion Plan (hereinafter also the 'DEIPlan'), and for which Performance Indicators (KPIs) have been identified forthe purpose of measuring and monitoring them:-Culture and strategy: improvement of the organization's working

environment by promoting and supporting inclusion, gender equality andenhancing gender diversity;-Governance: implementation of a governance model within theorganization that defines the appropriate organisational safeguards and thepresence of the minority gender in the organization's governance and control
bodies, as well as processes for identifying and remedying any case of noninclusion;-HR processes: implementation of HR processes relating to different

stages of a resource's life cycle within the organization, based on theprinciples of inclusion and respect for diversity;

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Version No. 01-Opportunity for the growth and inclusion of women in the company:

improvement of the organization's ability to ensure gender-neutral access toand acceleration of internal career and growth paths;-Gender pay equity: implementation of processes for the balancing ofremuneration;-Parental and family protection and work-life balance: implementationof policies to support staff in their parental care activities.

5. IMPLEMENTATIONThe Parent Company and other Companies subject to the OTB Group's
direction and coordination undertake to implement and adopt this Policy,
without prejudice to their own specificity and independence.
Each Company ensures the correct and constant application of what is set
out herein and its widest possible dissemination within the company and tostakeholders, in compliance with its confidentiality obligations, its autonomyand independence.

6. COMMUNICATION AND DISSEMINATIONThe OTB Group undertakes to communicate and disseminate the principles
laid down in this Policy within the organization and to all its stakeholders,through identified internal and external communication processes.

Internal communication processes
Internal communication processes, such as the company newsletter,
feedback procedures, physical or digital communications to employees, mustensure the achievement of the objectives identified by the Group:-use procedures and tools that are fully accessible in physical, linguistic

and cultural terms;-ensure the dissemination of inclusive strategies to strengthen an

organisational model among people that is aimed at respecting andenhancing diversity and gender equality;
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-train and raise awareness among employees at all levels, including

management, with regard to the issues covered by this Policy.

External communication processes
External communication processes, namely all those activities aimed atcommunicating with the public, through physical or digital channels, mustensure the achievement of the following objectives:-ensure the propagation of a language geared towards inclusion andgender equality, highlighting its added value;-ensure equal gender representation among speakers at all panels,

workshops, conferences or other events, including scientific ones, in which
the Group takes part;-use external communication tools that can be easily accessed andused by stakeholders.

This Policy is also communicated to all employees and is made available toall stakeholders on the OTB Group's corporate intranet and website.

7. MONITORING AND REVIEWThis Policy is regularly monitored and updated by the DEI Committee with thecoordination of the DEI manager appointed by the Committee.
The members, roles and methods for such monitoring and review aredescribed in the DEI Committee Regulations.
In relation to this Policy, the DEI Committee:-defines, assesses and monitors the effectiveness of the Diversity,

Equity and Inclusion Policy, making proposals for updates where necessary;-reviews and modifies/confirms the effectiveness of the approachadopted on the basis of events, changes and the results of monitoring andaudits.

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The OTB Group encourages all recipients of this Policy to report, inaccordance with corporate procedures, any conduct that is not in line with theprinciples set out herein and any alleged or certain violation of the same.

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