CODE OF ETHICSSENSI VIGNE E VINI SRL Via Cerbaia, 107 - 51035 Lamporecchio (PT) - P.IVA/C.F. 00183820471
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CODE OF ETHICSSTATUS OF THE REVISIONREVISION No.

DATE OF UPDATEPAGES REVISEDREASON0

12/05/2016---

First issue1

22/12/2017---

New issue

2

07/07/2023---

Mandatory work requirements,
report on client protocols
and sustainability policies are
better speciﬁed

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CONTENTSCONTENTS ........................................................................................................................................................................... 2
1. PREMISE ............................................................................................................................................................................ 3
2. THE OBJECTIVE ................................................................................................................................................................ 4
3. GENERAL PRINCIPLES ..................................................................................................................................................... 5
3.1 HONESTY ..................................................................................................................................................................... 5
3.2 FAIRNESS IN POTENTIAL CONFLICTS OF INTEREST ................................................................................................. 5
3.3 CONFIDENTIALITY ........................................................................................................................................................ 5
3.4 VALUE OF HUMAN RESOURCES AND LABOUR-SPECIFIC REGULATORY ASPECTS ................................................ 5
3.4.1 CHILD LABOUR ............................................................................................................................................................ 5
3.4.2 FORCED LABOUR ........................................................................................................................................................ 6
3.4.3 COLLECTIVE CONTRACTS AND FREEDOM OF ASSOCIATION ............................................................................... 7
3.4.4 DISCRIMINATION ........................................................................................................................................................ 7
3.4.5 DISCIPLINARY PROCEDURES ..................................................................................................................................... 8
3.4.6 WORK SCHEDULE ....................................................................................................................................................... 9
3.4.7 PAY ............................................................................................................................................................................... 9
3.5 THE VALUE OF THE ENVIRONMENT ......................................................................................................................... 10
3.6. FAIRNESS OF AUTHORITY ........................................................................................................................................ 10
3.7 INTEGRITY AND PROTECTION OF THE INDIVIDUAL ............................................................................................... 10
3.8 TRANSPARENCY, COMPLETENESS AND TRUTH OF INFORMATION ...................................................................... 10
3.9 CONTRACT FULFILMENT AND RE-NEGOTIATION ................................................................................................... 10
3.10 QUALITY, SAFETY AND ENVIRONMENTAL POLICY ................................................................................................ 11
3.11 RESPECT FOR HEALTH AND SAFETY IN THE WORKPLACE ................................................................................... 12
3.12 FAIR COMPETITION ................................................................................................................................................... 13
3.13 USE OF COMPANY ACCESS TO THE INTERNET ..................................................................................................... 13
3.14 PROHIBITION AGAINST ACTIVITIES THAT ARE TERRORISTIC OR SUBVERSIVE TO THE DEMOCRATIC ORDER .13
4. PREVENTION OF CRIMES IN RELATIONS WITH THE PUBLIC ADMINISTRATION ..................................................... 14
5. CORPORATE CRIME PREVENTION ............................................................................................................................... 14
6. PREVENTION OF OFFENCES AGAINST THE INDIVIDUAL .......................................................................................... 14
6.1. PROHIBITION OF CHILD PORNOGRAPHY AND DETENTION OF PORNOGRAPHIC MATERIAL ........................... 14
7. THE DUTIES OF THE SUPERVISORY BOARD IN RELATION TO THE IMPLEMENTATION AND OBSERVANCE OF THE CODE OF ETHICS .15
7.1 COMMUNICATION AND TRAINING ........................................................................................................................... 16
7.2 REPORTS FROM INVOLVED SUBJECTS ...................................................................................................................... 16
7.3 ANNUAL REPORT OF THE SUPERVISORY BOARD ..................................................................................................... 16

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1. PREMISE
Undoubtedly today the introduction of a “code of ethics” as an instrument of corporate professional ethics
represents the key for the development of competitivity and success of every entrepreneurial endeavour.
Sensi Vigne & Vini s.r.l., a family concern that produces, bottles and sells wine according to wine making
tradition, refers to this Code. The Sensi family actively participates in every aspect of running the businessand collaborates with its employees for their mutual benefit. Company management is geared towards
development and innovation and the aim is to combine these aspects with the wine making tradition ofboth the Sensi Family and the region of Tuscany. Sensi Vigne & Vini s.r.l., strives to observe the following
standards/laws:• national laws and regulations (hereby refer to the individual chapters of this section);• the national labour collective agreement that applies to the employees of the business;• the regulations of the state agencies that govern employment contracts.
The purpose of the code of ethics is to guide the employees and the ownership towards maintaining a conduct,
in internal and external activities, that promote the image of their work as a concrete example of fairness andprofessionalism in the world, favouring the company’s good name and attracting the trust of operators andtherefore favouring the Company’s development to the benefit of everyone involved.
For this purpose it is necessary to understand how conduct, if not aligned with this set of rules, can cause
serious and crucial damage to the Company which said company cannot afford and does not wish to be
subjected to. Plus it is important to understand that in a world where communication seems very easy, it
is actually a very delicate aspect and regardless of the means that we all have at our disposal, it is necessary
to be very careful of how we communicate and what we communicate. In sum: the first product that acompany sells is trust and its first form of communication is conduct. Therefore all collaborators are asked tounderstand and follow the requirements of this code and make them part of their own fundamental principles
so that they become the very pillars of all conduct, given that Sensi’s reputation stems from the actions of thecompany’s collaborators.
Sensi Vigne & Vini s.r.l. does not tolerate offending conduct nor the failure to observe the principles of thiscode and every violation will entail due decisions.
In addition to the requirements of this document, Sensi Vigne & Vini s.r.l. strives to respect any protocols
that its customers may require to observe and to train and inform its company staff about the fundamental
elements of these protocols.

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2. THE OBJECTIVE
The company’s objective in writing this code of ethics is to emphasize employee, consumer and stakeholder
expectations in relation to correct conduct, in terms of moral integrity in work relations, including tradepractices with customers and suppliers, for the purpose of guaranteeing correct ethical conduct.
In observance of these values the company proceeded to write this “Code of Ethics”, as attached to theOrganisation and Management Model pursuant to Art. 6 Lgs.D. 231/2001 (in Italian ‘M.O.G’) with theobjective of continuing to spread the principles and standards to conduct so that they represent the pillars of
the company’s business. These elements are concretely implemented in every relation that the company holdswith third parties, including employees, external collaborators, customers and suppliers.
The Code of ethics that is not motivated exclusively by the observance of a regulation in force, but especiallya moral responsibility towards a professional tradition handed down over the years, fairness towards humanresources and respect for the environment. Consistently with the pre-established purposes, the Sensi Vigne &Vini s.r.l. Code of Ethics was organised into five chapters:• one chapter dedicated to the “general principles of conduct”, which provides the general principles of conductthat Sensi Vigne & Vini s.r.l. Employees, Social Agencies, Sales Agents, Consultants, External Collaborators
and Partners are required to observe;• three chapters (“Prevention of crimes in relations with the Public Administration”, “Corporate crime
prevention”, and “Prevention of offences against the individual”) dedicated to the specific conduct required of
Sensi Vigne & Vini s.r.l. Employees, Social Agencies, Sales Agents, Consultants, External Collaborators andPartners to avoid criminal charges:> set forth by Lgs.D. No. 231/2001;> in reference to which the prerequisite analysis for the introduction of the Organisation, management
and control model of the activities pursuant to Lgs.D. 231/2001, that the Code of Ethics is an integral
part of, has illustrated that there are theoretical/potential areas of risk;• a chapter on how the Code of Ethics is implemented.
A further motivation for the preparation of its own code of ethics is to set out the principles that will guidethe company towards a path of sustainable development which, according to Sensi Vigne & Vini s.r.l., must
temporarily take into account 3 elements:- environmental protection and efficiency in the use of materials and resources;- appropriate ethical and social behaviours, also involving people working in human resources in thecompany development, guaranteeing them rights and adequate remuneration;- creation of adequate added value. This element, which could be considered redundant, according
to company creed, must be developed together with the other elements as its absence would be an

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irreplaceable element for the company development and the pursuit of the other elements of sustainable
development.
Lastly it is necessary to underline that this Code of Ethics is based on an ideal of cooperation in view of themutual benefit of the involved parties, with respect towards the role of each. Accordingly, Sensi Vigne & Vini
s.r.l., requires each involved subject to conduct him/herself in relation to the company in keeping with theprinciples and rules of ethical conduct.

3. GENERAL PRINCIPLES
3.1 Honesty
The essential principle at Sensi Vigne & Vini s.r.l. is the observance of the laws and regulations in force.
Therefore, within the scope of their professional activities, the Employees and Social Agencies of Sensi
Vigne & Vini s.r.l., as well as its Sales Agents, Consultants, External Collaborators, Partners, suppliers andcustomers, and anyone holding relations with them, are required to diligently observe the laws and regulations
in force. Under no circumstance can the pursuit of Sensi Vigne & Vini s.r.l.’s interests justify dishonest
conduct, pursuant to this paragraph.
Sensi Vigne & Vini s.r.l. will not begin nor continue any relation with anyone who does not intend tomaintain this principle. The Employees and Corporate Bodies of Sensi Vigne & Vini s.r.l. must be familiar
with the laws and relative conduct; when in doubt on how to proceed within the scope of their activities,
they can ask for explanations from the Supervisory Board odvsensi@sensivini.com which will promptly duly
inform the interested parties.
3.2 Fairness in potential conflicts of interest
The running of a business must always avoid, including potential, situations of conflict of interest, namely
situations where an Employee, a member of a Corporate Body, a Sales Agent, a Consultant, and External
Collaborator or a Partner pursues an interest that does not pertain to Sensi Vigne & Vini s.r.l. and thebalancing of interests of involved subjected or achieves personal gain from the company’s business deals.
3.3 Confidentiality
Sensi Vigne & Vini s.r.l. guarantees the confidentiality of the information in its possession and abstains

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6 of 20from performing searches of confidential data, except for cases where it has received express and conscientious
authorisation and the searches are conducted in compliance with the legal standards in force. In particular,
Sensi Vigne & Vini s.r.l. Employees, Corporate Agencies, Sales Agents, Consultants, External Collaborators
and Partners are required to not use confidential information acquired in relation to the Sensi Vigne & Vini
s.r.l. business for aims that are not connected to the performance of their activities.
3.4 Value of human resources and labour-specific regulatory aspects
Sensi Vigne & Vini s.r.l. considers Employees and External Collaborators as a crucial factor to its success and,
therefore, protects and promotes the value of its human resources with the aim of increasing and improving
the assets and the competitiveness of the competencies of each collaborator or employee in observance of thehealth and safety conditions in the workplace according to the M.O.G. (*Italian acronym for Organisationand Management Model) system.
3.4.1 Child labour
Sensi Vigne & Vini s.r.l. does not allow the use of child labour and agrees to employ only staff over 18 yearsof age. It is the responsibility of the human resources Manager to monitor the staff selection and recruitment
stage so that each new hire is over the age of 18. Sensi also strives to create awareness among its suppliers
so they too avoid child labour and to guarantee any youth between the ages of 16 and 18 compatible work
conditions for their physical and mental development.
Reference legislation• UN Convention on the Rights of the Child• “Minimum Age” (L. 157/81)• “Worst forms of child labour” (L. 148/00)
3.4.2 Forced labour
Sensi Vigne & Vini s.r.l. strives to avoid the use of any form of coercion towards its staff. Each worker is free
to terminate his or her employment relationship with the company at any time. The company management
considers job satisfaction and motivation to be the only “anchors” that must bind employer and employee
and believes that this mechanism can be the only spur towards work productivity. For its staff the company
applies all of the regulations set forth by the regulation in force and by the National Labour Collective
Agreement. In order to make work activities fully voluntary, Sensi informs all workers of their rights andduties deriving from the National Labour Collective Agreement and other applicable legal regulations (ex. theSENSI VIGNE E VINI SRL Via Cerbaia, 107 - 51035 Lamporecchio (PT) - P.IVA/C.F. 00183820471
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Statute of Labourers), making the regulation available to anyone wishing to consult it. The company’s RLS
also identifies the worker who has the duty to inform and assist workers in relation to occupational safety.
Workers are free to leave the workplace at the end of their work shift. The company does not use guards orother manners of controlling workers. Private security is only used for the purpose of night surveillance of thecompany facility. Workers are familiar with the rules pertaining to the necessary notice period to receive thelast pay cheque (as stated in the reference National Labour Collective Agreement). The company does not
require whatsoever its staff to provide the following at the beginning of their work contract:> deposits of any kind, in money or in kind;> originals of documents, except for those required by law.
Sensi Vigne & Vini s.r.l. fights the use of undeclared employment, the gang-master system or any contractual
form that violates of avoids the legal requirements. All workers are hired with contract in accordance with theregulations in force. The human resources Manager has the task of observing the regulation in force, checking
and ensuring the correct application of the duties required by the laws on established employment contracts.
Sensi Vigne & Vini s.r.l. also condemns all forms of abuse and harassment against its collaborators, regardlessof the reasons for which such behaviours might be justified.
Reference legislation• “Forced labour” (L. 274/34)• “Abolition of forced labour” (L. 447/67)• L. 300/70 – Statute of Labourers• National Collective Labour Agreement
3.4.3 Collective contracts and freedom of association
Sensi Vigne & Vini s.r.l. guarantees all workers the right to join any trade union and the possibility ofelecting union representatives, guaranteeing all of the rights set forth in the C.C.N.L. (Italian acronym for
National Labour Collective Agreement) regulations in force. The company guarantees the collective contract
through the full application of the C.C.N.L. (Italian acronym for National Labour Collective Agreement). If
exceptions need to be made to the C.C.N.L. (Italian acronym for National Labour Collective Agreement), thecompany agrees on these exceptions with the trade union representatives.
The company guarantees the free election of union representatives, ensuring them with the possibility ofcommunicating with the members at the workplace, participation in general meetings and meetings.
The company prevents every form of discrimination towards union members or representatives. The staff
manager has the task of checking observance of the pertaining regulation in force, to ensure the correct
application of the duties stemming from the laws on relations with union representatives and the application
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Reference legislation• “Trade union freedom and protection of trade union law” (L. 367/58)• “Right to collective organisation and negotiation” (L. 367/58)• “Workers’ Representatives” (L. 157/81)• L. 300/70 – Statute of Labourers• National Collective Labour Agreement
3.4.4 Discrimination
Sensi Vigne & Vini s.r.l. refutes every form of discrimination and guarantees equal opportunities and equal
treatment to all workers, regardless of race, class, national original, religion, disability, gender, sexual
orientation, trade union and political affiliation, age. Accordingly the company:• makes the selection taking into exclusive consideration objective elements such as ability, experience andeducation in relation to the positions to be filled• pays each worker a salary based on the tasks that they perform in accordance with the C.C.N.L. (Italianacronym for National Labour Collective Agreement)• guarantees instruction and training to everyone based on personal needs and the company’s organisationaland management needs.
• promotes individuals based on their abilities and the company’s organisational and management needs• places people in retirement according to the pertaining regulations in force• only fires employees for cases allowed by the law and in any case never for discriminatory reasons.
The company also favours the recruitment of women workers, also through the application of forms of
support to maternity, as set forth by the law and the collective agreement.
The company guarantees, when requested by the worker, the possibility to avail of holidays and leave and toschedule work shifts based on production needs, also in consideration of particular religious needs.
The company is aware of the differences between cultures and religions and guarantees each worker that his/her principles, faith and opinions of any kind will be respected as long as they do not breach the regulations inforce.
The company does not accept the use of physical or verbal behaviours that represent any form of physical or
moral violence towards any worker.
The Staff manager monitors observance of the regulation, so as to guarantee that no form of discrimination
occurs in the work relations.
To allow anyone subjected to discrimination to defend them-self and report the discrimination, Sensi Vigne
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9 of 20& Vini s.r.l. has set up due procedures, responsibilities and channels of communication as described inparagraph 7.2.
Reference legislation• “Pay equality” (L. 741/56)• “Discrimination (occupation and profession)” (L. 405/63)• “Professional reintegration and occupation (disabled individuals)”• UN Convention to eliminate all forms of discrimination against women• Lgs. D. 151/01 – Consolidation Act of regulation on the protection of and support to maternity
and paternity• National Collective Labour Agreement
3.4.5 Disciplinary procedures
Sensi Vigne & Vini s.r.l. does not allow the use if any disciplinary practice outside of the law and the
National Collective Labour Agreement and especially any practice (whether corporal punishment, mental andphysical coercion, verbal abuse) that can damage the physical and moral integrity of its employees.
Sensi Vigne & Vini s.r.l. allows the use of disciplinary sanctions with the aim of maintaining good relations
between workers, which includes their supervisors and towards customers. Availing of disciplinary proceduresis implemented in accordance with the Statute of labourers (Law 300/70), laws 604/66 and 108/90 andthe articles of the National Collective Labour Agreement applied in companies relative to the “Disciplinary
Code”.
The human resources Manager ensures that the regulation governing the application of disciplinary procedures
is observed, ensuring that no sanction is issued unless it is in observance of the law and the applied National
Collective Labour Agreement.
Reference legislation• “Forced labour” (L. 274/34)• Regulations on individual dismissal (L. 604/66 as amended – L. 108/90)• Statute of labourers – Disciplinary power and disciplinary dismissals (L. 300/70)• National Collective Labour Agreement
3.4.6 Work scheduleSensi Vigne & Vini s.r.l. applies the work schedule established by the national labour collective agreement
which is currently a maximum of 40 hours per week, with at least two out of 7 days off while any extra hours
are voluntary.
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10 of 20Extra hours, which must not in any case exceed the limits set forth in the regulation, and work carried out
on bank holidays are/is paid more than regular work hours, as set forth in the national labour collective
agreement.
Reference legislation• “Convention on the right to collective organisation and negotiation”• National Collective Labour Agreement
3.4.7 Pay
Sensi Vigne & Vini s.r.l. guarantees all of its employees fair, dignified pay that fulfils the requirements of
the national labour collective agreement. The company also provides forms of integration at the minimum
levels set by the national labour collective agreement based on capability and professionalism. To assist its
employees, the company also follows their processes that concern: the request to receive family allowancecheques, deductions and other forms of integration to the minimum wages set in the national labour collective
agreement and, in case of need, provides advances and loans to its workers. Only for this purpose, at the timeof hiring, the company asks the worker for information concerning the income of his/her spouse and thenumber of dependent children.
No amounts of wages are withheld for disciplinary reasons: any amounts withheld are only for tax purposes.
Pay cheques expressly indicate all of the entries relative to amounts due and amounts withheld: the personnel
office is also available for any relative explanations.
Wages are paid monthly by the 15th of the following month, as required by the national labour collective agreement(if this day is a holiday the pay cheque will be available on the first business day thereafter). Wages will be paid
through bank transfer.
The company acknowledges the value and use of internship, apprenticeship and job training contracts fortraining purposes as stated by the legislation, within the restrictions set forth by the law.
Reference legislation• c 100 “Convention concerning Equal Remuneration for. Men and Women Workers for Work ofEqual Value” - 1951
• l. 300/70 – Statute of Labourers• National Labour Collective Agreement
3.5 The value of the environment
Sensi Vigne & Vini s.r.l. considers respect for the environment as crucial for its growth in the field it works
in and, therefore, the company protects and promotes minimising the impact on the environment with the
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aim of increasing and improving the awareness of each collaborator or employee on respecting the procedures
defined by the M.O.G. (*Italian acronym for Organisation and Management Model) system, also bottling
products in bio or vegan lines.
The company management also promotes and invests its own resources to reduce environmental impacts and,to this end, the activities that are pursued are:
- Promoting an efficient use of energy resources used and the production from renewable sources;- Disposing of processing wastes in accordance with current regulations and environmental
authorizations, providing for their purification;- Reducing the waste of materials, always favouring their reuse and a proper storage and disposal ofwastes produced;- Reducing the waste of water resources, in compliance with food safety requirements that must always
be guaranteed;- Prioritising the reduction of chemicals consumption, also through the production of organic andwithout added sulphites wines.
3.6 Fairness of authority
Sensi Vigne & Vini s.r.l. is committed to ensuring that authority is always exercised within hierarchicalrelations based on criteria of equality and fairness and does not imply the occurrence of abuse of any kind.
In particular, Sensi Vigne & Vini s.r.l. ensures that authority does not turn into the exercise of power thatdamages the dignity and independence of the Employee or External Collaborator and that work organisation
choices are made whilst protecting the value of the Employees or External Collaborators.
3.7 Integrity and protection of the individual
Sensi Vigne & Vini s.r.l. agrees to protect the moral integrity of its Employees or External Collaborators,
guaranteeing the right to work conditions that are respectful of personal dignity. For this reason the company
protects workers against acts of mental violence, and fights any attitude or discriminatory or harmful conductagainst the individual, of his/her beliefs and preferences (for example, insults, threats, isolation or excessive
intrusion, professional limitations). Sexual misconduct is not admitted and it is necessary to avoid conduct
and dialogue that could offend personal sensitivity (for example, exposure to images containing explicit sexualreferences, insistent and persistent allusions). Sensi Vigne & Vini s.r.l. Employees or External Collaborators
who feel they have been subject to sexual misconduct or discriminated against for reasons concerning age,gender, sexuality, race, health conditions, nationality, political opinions and religious beliefs etc, can report
the incident to the Chairman of the Board of Directors and to the Supervisory Board pursuant to Lgs. D. No.
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12 of 20231/2001, who will assess whether the Code of Ethics was violated.
3.8 Transparency, completeness and truth of information
Sensi Vigne & Vini s.r.l. Employees or External Collaborators are required to provide complete, transparent,
truthful, comprehensible and accurate information, so that, when establishing relations with the company,
the involved subjects and anyone coming into contact with the company, are/is able to make independentand conscientious decisions on the involved interests, on possible alternatives and significant implications. In
particular, when preparing any contracts, Sensi Vigne & Vini s.r.l. is required to specify to the contracting
party what conduct he/she must adopt in all possible circumstances, in a clear and understandable manner, inrespect of the criteria established in the M.O.G. (*Italian acronym for Organisation and Management Model).
3.9 Contract fulfilment and re-negotiation
Contracts and work appointments must be fulfilled in accordance with what is voluntarily agreed by theparties. To this regard it is necessary to highlight that Sensi Vigne & Vini s.r.l. agrees:• not to exploit circumstances of ignorance or inability (including temporary) of its counterparties;• to avoid, in existing relations, anyone working in its name or on its behalf from trying to take advantage ofcontractual loopholes or unforeseen events, to re-negotiate the contract with the aim of exploiting the positionof dependence or weakness that the other party finds him/herself in.
3.10 Quality, safety and environmental policy
Sensi Vigne & Vini s.r.l. believes that the company’s success is strictly connected to the integrated
management of processes required to provide what Customers ask for, in terms of product and service
conformity and respect for the health and safety of its employees. The primary objectives are:
1. Customer Satisfaction: the key to success is in complete Customer Satisfaction, to fulfil the Customer
in terms of product and service;
2. Professional integrity: loyalty and fairness in relations and fully sharing corporate objectives;
improving sensitivity, the spirit of collaboration and the entire staff’s attention to quality aspects;
3. Observance of the law: observing laws, standards, regulations, undersigned commitments applicableto the product/service, to Health and Safety in the Workplace and to the Environment;
4. Injury reduction: the objective to reach zero injuries and zero occupational diseases within an

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approach of prevention, thanks to the definition of a Health and Safety Management System and an
Organisation and Management Model that exempts administrative responsibility, as per Lgs. D. No.
231 of 08/06/01 as amended.
5. Cost containment: streamlining corporate processes for the purpose of reaching the maximum level of
efficacy and efficiency;
6. Continuous improvement: the continuous improvement of processes and products, for the purpose ofmaintaining high Competitiveness.
Sensi Vigne & Vini s.r.l. considers quality as fulfilling Customer needs, as seen as an integral part of an
inseparable combination which, for the industry, translates into compliance and reliability of the product andpromptness of the service and before and after sales assistance. Involving and training staff, the availability ofsuitable resources (systems, testing equipment and materials), the selection and growth of qualified suppliers
represent the winning criteria for reaching quality-related objectives.
Sensi Vigne & Vini s.r.l. believes that the health and safety of its employees is the top priority in the
management of its activities: this objective is pursued through observance of the legislation in force andthe applicable regulations and thanks to the definition of improvement procedures and plans that prevent
undesirable events such as injuries and occupational diseases from occurring.
Sensi Vigne & Vini s.r.l. appointed the Prevention Protection Service Manager with the task of monitoring
all aspects connected to occupational Health and Safety by identifying and monitoring the risk factors,
identifying all of the preventive and protective measures for the health and safety of the workers and providing
the workers with information and training. The company has also given workers the possibility to elect asafety representative, with the function of controlling and interacting with the Prevention Protection Service
Manager on all identified risk factors, and checking that the Manager effectively implements the corrective
actions. All staff is given suitable information material and periodic training is conducted on the required
fulfilments. The Prevention Protection Service Manager provides the following either directly or throughspecialised instructors:• general and specific information courses for particularly risky activities,• training courses for new hires and for workers who may have changed their professional duties,• training courses for appointed fire emergency and first aid persons.
The company has identified, purchased and provided free of charge to its employees the Personal Protective
Equipment necessary for the health and safety of their work: the Prevention Protection Service Manager andthe supervisors constantly monitor actual use and periodically inspect the state of wear and adequacy.
In case of wear or inadequacy, the Production Manager immediately replaces the PPE.

SENSI VIGNE E VINI SRL Via Cerbaia, 107 - 51035 Lamporecchio (PT) - P.IVA/C.F. 00183820471
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The Prevention Protection Service Manager constantly monitors all the risk factors that may affect the safety
and health of workers and, in collaboration with top management, periodically inspects maintenance activities
to ensure that the safety equipment and devices are working correctly.
The Prevention Protection Service Manager provides and coordinates with the company’s Quality Manager(Italian acronym RQ) to guarantee the availability of all the technical data sheets of the equipment and thesafety data sheets of the chemical products at the facility and accessibility to all workers.
Reference legislation• Lgs. D. 81/2008 as amended - Consolidated Act on worker health and safety• Risk assessment documents and their attachments
Sensi Vigne & Vini s.r.l. is aware of the importance of preventing environmental crimes that entail
administrative responsibility within the application of Lgs.D. 231/01, which briefly refer to the following:
1. Water sewers systems;
2. Pollution of the soil, subsoil, surface water or ground water;
3. Collection, transport, recovery, disposal, trade and intermediation of waste;
4. Waste management;
5. Ozone depleting substance management;
6. Habitat depletion
Sensi Vigne & Vini s.r.l. applies the Risk-Assessment to promptly identify the subsistence of the individual
crimes, including environmental, and to assess the risk of them being committed. The assessment is carriedout by analysing company processes. If necessary, the support of a specialised external professional is calledupon.
The commitments for Quality, Health and Safety and for the Environment translate into annual plans ofobjectives and measurable indicators, assigned to the various levels of the corporate structure.
The Quality, Health and Safety Policy is implemented daily by all staff and under the constant attention
and supervision of the Quality Manager and the RSPP (Italian acronym for Protection Prevention Service
Manager); periodically (see “Management Review” procedure and the “Instruction and Training” procedure)
the Management organises meetings to spread the principles, objectives and commitments for the corporate
management of these aspects. Management promotes the application, improvement and development of thesystem and makes sure that the contents of the manual, the Procedures and the Instructions are disseminated,
understood and shared by all employees and collaborators.

SENSI VIGNE E VINI SRL Via Cerbaia, 107 - 51035 Lamporecchio (PT) - P.IVA/C.F. 00183820471
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3.11 Respect for health and safety in the workplace
Sensi Vigne & Vini s.r.l. implements the necessary measures to ensure the best possible protection of healthand safety in the workplace and the prevention of all potential forms of risk. It also defines a policy to ensure
the best possible protection for health and safety in the workplace and prevention against all potential formsof risk with a view towards the continuous improvement that the company sets for itself. This policy applies
equally to the company’s own employees as well as the staff of external companies, within the scope of theiractivities at the Company’s sites. To develop and control the observance of the management of Health and
Safety, the Company avails of an implemented system, founded on the Risk Assessment Document and its
own Quality, Environment and Safety Policy. To develop and control the observance of the management of
Health and Safety, the Company avails of an articulated system which involves:
1. a targeted corporate organisation that identifies the level of responsibility, the division of tasks and the levelof independence of each position in the organisation;
2. the Quality, Safety and Environment agency which, alongside Management, represents the competentcentre to create the conditions to achieve shared results that fulfil the company’s ethical values. It is incharge of the management aspects, developing the necessary documentation for the Integrated Quality, Safety
Management System (manual, procedures, instructions, forms) in collaboration with the Prevention andProtection Service, for the aspects relating to Health and Safety, and with the involved Agencies.
3. a management system for the aforementioned procedures, stemming from the Risk Assessment Document,
which specifies the risks and indicates the operating modes;
4. a system of operational instructions, stemming from the management procedures system, which indicates, indetail - if necessary - how work is carried out safely.
5. a system of printed and electronic records, stemming from the operational instructions system, which
provides objective evidence of the completed activities and the obtained results
All employees, collaborators and third parties are required to strictly observe all of the measures requestedby the Sensi Vigne & Vini s.r.l. procedures and internal regulations, in relation to Health and Safety in theworkplace, elaborated and updated in compliance with the legislation in force. In particular, each individual is
asked to report any observations relative to dysfunctions or possible improvements to his/her supervisor.
3.12 Fair competition
Sensi Vigne & Vini s.r.l. intends to protect the value of fair competition and accordingly abstains fromconduct that is deceitful, predatory or characteristic of abuse of dominant position.

SENSI VIGNE E VINI SRL Via Cerbaia, 107 - 51035 Lamporecchio (PT) - P.IVA/C.F. 00183820471
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3.13 Use of company access to the Internet
Sensi Vigne & Vini s.r.l. strives to avoid the use of company access to the Internet for reasons that are notstrictly pertinent to work activities and, in particular, forbids its use to come into possession of and distribute
pornographic material (especially when relating to individuals under the age of 18). Subsequently, in order toavoid harming the company’s image:• procedures may be implemented through the use of “filters” to prevent Sensi Vigne & Vini s.r.l. Employee
access to Internet sites that display pornographic material;• Sensi Vigne & Vini s.r.l. employees are nevertheless strongly advised to avoid accessing Internet sites that
display pornographic material.
3.14 Prohibition against activities that are terroristic or subversive to the democraticorder
Sensi Vigne & Vini s.r.l. is against any form of activity carried out for the purpose of terrorism or subversion
to the democratic order. Accordingly, in order to avoid harming the company’s image:• Sensi Vigne & Vini s.r.l. Employees, members of the Social Agencies, Sales Agents, Consultants, External
Collaborators and Partners are forbidden from performing any form of activity with the intention ofterrorism or subversion to the democratic order;• any Sensi Vigne & Vini s.r.l. Employee with the founded suspicion that one of his/her co-workers is
conducting activities with terroristic or subversive intentions must immediately inform the public safety
authorities as well as the Board of Directors and the Supervisory Board pursuant to Lgs. D. No. 231/2001,
who will take every initiative to actively collaborate with the aforementioned authority.

4. PREVENTION OF CRIMES IN RELATIONS WITH THE PUBLIC ADMINISTRATION
In order to prevent conduct that could violate the law and regulations, if there are relations with the public
administration Sensi Vigne & Vini s.r.l. will endeavour to avoid conduct considered as foul and contrary to
the professional ethics and therefore the company’s ethics, which includes:• offering money or gifts to executives, officers or employees of the Public Administration or their relatives,
both Italian and foreign;• offering any object, service, competence or favour of value to obtain preferential treatment in any relation

SENSI VIGNE E VINI SRL Via Cerbaia, 107 - 51035 Lamporecchio (PT) - P.IVA/C.F. 00183820471
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17 of 20with the Public Administration;• when any business negotiation, request or relationship with the Public Administration are in progress,
trying to inappropriately sway the decisions of the counterparty including officers who partake in or makedecisions on behalf of the Public Administration;
Lastly, for precautionary purposes, Sensi Vigne & Vini s.r.l. agrees to:• select its Partners from subjects who, by market share, by specific technical skills or by long duration of theirstanding on the market, are acknowledged as leaders or at the highest levels in the reference market.
• Any violation (effective or potential) of the rule of conduct included in this paragraph, committed by Sensi
Vigne & Vini s.r.l. staff or third parties, must be promptly reported to the Board of Directors and theSupervisory Board pursuant to Lgs. D. No. 231/2001.

5. CORPORATE CRIME PREVENTION
Sensi Vigne & Vini s.r.l. firmly believes in the need to establish relationships with audit firms, othercontrol bodies and public vigilance authorities (that carry out control/review activities legally attributed toshareholders, to other corporate bodies or to auditing companies) based on loyalty, observance of the law andmutual collaboration in order to ensure compliance with the interests of the involved parties and ensure thecorrect and complete performance of control and auditing activities. For this purpose it is forbidden:• for Sensi Vigne & Vini s.r.l. Administrators to withhold documents or use other suitable devices to preventor obstruct control or revision activities legally attributed to shareholders, to other corporate bodies or to
auditing companies from being conducted;• for Sensi Vigne & Vini s.r.l. Employees from collaborating in any illicit conduct of the revision manager
aimed at attesting falsehoods or withholding information on the company’s economic, asset-related andfinancial situation.

6. PREVENTION OF OFFENCES AGAINST THE INDIVIDUAL
6.1 Prohibition of child pornography and detention of pornographic material
To avoid Sensi Vigne & Vini s.r.l. Employees, members of Corporate Bodies and Collaborators fromSENSI VIGNE E VINI SRL Via Cerbaia, 107 - 51035 Lamporecchio (PT) - P.IVA/C.F. 00183820471
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committing child pornography crimes (art. 600-ter of the Italian criminal code) and the detention of
pornographic material (art. 600-quater of the Italian criminal code) and thereby damage Sensi Vigne & Vini
s.r.l.’s image, they are forbidden from:• exploiting children under 18 for the production of pornographic performances or the production of
pornographic material and the sale of the aforementioned pornographic material;• distributing, disclosing, advertising the aforementioned pornographic material through any means,including electronic;• distributing or disseminating news/information aimed at sexually grooming or exploiting children under 18;• knowingly obtaining or disposing of pornographic material produced through the sexual exploitation ofchildren under the age of 18.
Sensi Vigne & Vini s.r.l. is strongly committed to preventing its Employees, members of the Corporate
Bodies or Collaborators from committing crimes of tourism-related initiatives aimed at the exploitation ofchild prostitution (art. 600-quinquies of the Italian criminal code) and thus damage the image of Sensi Vigne& Vini s.r.l. It is therefore forbidden for Sensi Vigne & Vini s.r.l. Employees, members of the Corporate
Bodies and Collaborators to organise or engage in propaganda for trips aimed to participate in prostitution
activities to the detriment of minors or in any case involving such activities. Sensi Vigne & Vini s.r.l.
declares to extend the prohibitions referred to in the above paragraphs to every kind of pornographic activity
as well as every form of prostitution even when involving consenting adults.

7. THE DUTIES OF THE SUPERVISORY BOARD IN RELATION TO THE IMPLEMENTATIONAND OBSERVANCE OF THE CODE OF ETHICS
In order to guarantee the effective implementation and observance of this Code of Ethics, pursuant to Lgs.
D.No. 231/2001, the following tasks are assigned to the Supervisory Board:• overseeing the communication and training activities of the Code Of Ethics;• receiving and analysing reports from subjects relating to violations of the Code of Ethics;• preparing annual reports for the use of the Shareholder’s Meeting;• preparing an annual report (to be inserted in a specific chapter of the Financial Statements Report) on theactivity carried out during the relative year in relation to compliance with the Code of Ethics

SENSI VIGNE E VINI SRL Via Cerbaia, 107 - 51035 Lamporecchio (PT) - P.IVA/C.F. 00183820471
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7.1 Communication and training
The Code of Ethics is shared with the involved internal and external subjects through the following specificcommunication activities:• delivering a copy of the Code to every Sensi Vigne & Vini s.r.l. Employee;• formally declaring that the Code of Ethics is binding for all Employees, from a disciplinary point of view,shared through internal circular and by posting said notice in the premises where corporate activities are
conducted and accessible to everyone;• providing dedicated sections on the company Intranet;• requiring Sensi Vigne & Vini s.r.l. trade management to implement the Code;• publishing it on the Sensi Vigne & Vini s.r.l. website;• including express termination clauses in supply or collaboration contracts (agency, partnership, ...) that
explicitly refer to compliance with the provisions of the Code of Ethics;• preparing an annual report on the activity carried out by the Supervisory Board to be published for the
Shareholders’ Meeting for the approval of the Financial Statements (with the inclusion of a specific chapter in
the Financial Statement Report on the activity of the Supervisory body).
In order to ensure a correct understanding of the Code of Ethics to all new Employees and Collaborators at
Sensi Vigne & Vini s.r.l., the Supervisory Body pursuant to Legislative Decree No. 231/2001 prepares andconducts, within the first quarter of the new collaboration, also considering the indications of the Chairmanof the Board of Directors, various training initiatives according to the role and responsibility of the Employees
or Collaborators. Sensi Vigne & Vini s.r.l. strives to respect any protocols that its customers define and to
train and inform its company staff about the fundamental elements of these protocols.
7.2 Reports from involved subjects
All involved Sensi Vigne & Vini s.r.l. subjects may report, in writing, also in anonymous form (odvsensi@
sensivini.com), any violation or suspected violation of the Code of Ethics to the Supervisory Body pursuant
to Lgs.D. No. 231/2001, or by contacting the Body by phone at the numbers on the bulletin board, whereby
said Body will investigate the report, possibly hearing the author and the person responsible for the alleged
violation. For events that may involve employees, the specific procedure P.MOG.02 shall apply. With regards
to these reports, the Supervisory Board will do the following:• protect the authors of the reports against any form of retaliation (i.e. aimed at creating a form ofpunishment or discrimination);• ensure the confidentiality of the identity of the author of the report, unless otherwise required by law.
SENSI VIGNE E VINI SRL Via Cerbaia, 107 - 51035 Lamporecchio (PT) - P.IVA/C.F. 00183820471
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Sensi Vigne & Vini s.r.l. undertakes to implement any protocols of communication and reports of anomalous
acts that are contrary to the correct ethical and social behaviours that its customers may define and undertakes
to train and inform its company staff about the fundamental elements of these protocols.
7.3 Annual report of the Supervisory Board
At least annually, pursuant to Lgs. D. No. 231/2001, the Supervisory Board shall prepare a report for the
Shareholder’s Meeting, containing:• the list of communication and training activities carried out during the relative semester, and in particular
the indication of training activities regarding the Code of Ethics provided to any new Employees orCollaborators; violations of the Code of Ethics occurring during the quarter and any• suggestions on the implementation of provisions against the author of the violation;• suggestions for duly amending and integrating the Code of Ethics to keep it effective and up-to-date.
Pursuant to Lgs. D. No. 231/2001, at the Shareholder’s Meeting for the approval of the Financial Statement,
the Supervisory Board prepares a report with:• a summary of all the activities, controls and inspections carried out over the course of the year;• any update to the Code of Ethics;• other relevant topics;• annual plan of activities for the following year.

SENSI VIGNE E VINI SRL Via Cerbaia, 107 - 51035 Lamporecchio (PT) - P.IVA/C.F. 00183820471
Tel +39 0573 82910 Fax +39 0573 81751 Mail sensi@sensivini.com Web www.sensivini.com