GROUP BUSINESS AREAS NEWS AND MEDIA CONTACTS WORK WITH US EN Group / Governance / Organization model Choosing transparency “I believe that Coeclerici is exemplary, given the results the company has achieved all over the world. I am speaking, with a clear touch of pride, of one of the few, if not the only private company in Italy that has set itself governance rules that are far more advanced than those of many quoted companies: most of our directors are independent – neither family members nor shareholders – and most of our executive committee comes from outside the family. …This is what makes independent corporate governance possible, as well as what drives the need to adopt true transparency rules. The quality of basic external relations depends mainly on the quality of your operating methods. In the market, you’re judged by ‘what you do’ through ‘how you do it.’ Ethical aspects aside, the point is that correct conduct becomes an acknowledged value and, day after day, action after action, helps build the company’s credibility.” Chairman and CEO of Coeclerici Organization model Coeclerici (“The Company”) voluntarily adopted the Organizational Model for Italian Legislative Decree no. 231 of 8 June 2001. According to the Italian law “Responsibility of legal entities for administrative offenses”, entities, including corporations, can be responsible and therefore subject to penalties in relation to certain offenses committed or attempted – in Italy or abroad – on behalf or for the benefit of The Company. The Company has adopted the Organizational Model, a Code of Ethics and set up a Supervisory Board. Adoption of this Model is designed to create organic and structured procedures, rules and controls in order to prevent and / or substantially reduce the risk of committing one or more offenses covered by the Decree. The Model adopted by The Company is consistent with best practices established by industry associations, and is designed to reinforce transparency and accountability within the internal control environment. Any violation or suspected violation of this Model and / or any other information pertaining to its implementation may be reported to the Supervisory Board. Messages to the Supervisory Board can be sent in writing to the following address: Coeclerici S.p.A. Organismo di Vigilanza – c/o Internal Audit Piazza Armando Diaz n.7 20123 Milan (Italy) Organismodivigilanza@www.coeclerici.com Italian version: MODELLO ORGANIZZATIVO 231 CODICE ETICO English version: 231 ORGANIZATIONAL MODEL CODE OF ETHICS © 2021 Coeclerici Spa - Piazza Generale Armando Diaz 7, 20123 Milan, Italy - VAT Reg.No.: 00269690103 | Privacy Policy