MODEL 231 and CODE OF ETHICS Organizational model and ethical rules According to the provisions of Legislative Decree 8 June 2001 n. 231 , associative bodies, including joint stock companies, can be held liable in relation to certain crimes committed in their own interest or to the advantage of individuals belonging to top management or by employees, collaborators and external consultants. Delta Spa / Carifin Italia Spa in liquidation / Plusvalore Spa in liquidation / Adale Sistemi Srl / River Holding Spa / Holding Reti Spa in liquidation / Detto Factor Spa in liquidation has adopted an organization, management and control model pursuant to Legislative Decree n. 231 of 2001 in order to satisfy the necessary conditions for the exemption from the administrative liability of the Entity. The Company has also adopted a Code of Ethics , which provides that all company activities must be carried out in compliance with the law, according to the principles of seriousness, reliability, professionalism, integrity, honesty, fairness, respect and transparency, as well as respecting the interests own external interlocutors. These principles underpin the Company's commitment to uncompromising ethical conduct aimed at maintaining a solid and recognized reputation. REFERENCE DOCUMENTATION Model 231 - General Part Code of Ethics Tax Code, VAT number and reg. to the Company Reg. of Bologna n. 02308241203 - Share capital Euro 55,000,000.00 fully paid-up Company subject to the management and coordination of the Cassa di Risparmio della Repubblica di San Marino SpA