Codice di Condotta

1) INTRODUCTION

OTTAVIANI S.p.A. has decided to demonstrate transparency to its customers in the conduct of its
business activities by deciding to adopt a Code of Conduct. It is intended to represent a charter
of quality and guarantee for the user who, in the online mode, has no way of physically knowing
the place and the people. The principles set out below concern the company’s vision from a moral
and ethical perspective, values that this company has chosen as the focus on which to center its management.

2) HONESTY AND INTEGRITY

Honesty is a fundamental value that must always be considered in the performance of
work duties. The management of relationships, both with internal subjects and with collaborators,
partners, and customers, is based on criteria and conduct of integrity, cooperation,
loyalty, and mutual respect.

3) PROFESSIONALISM

OTTAVIANI S.p.A. is committed to maintaining professional conduct characterized by the
necessary diligence.

4) TRANSPARENCY AND COMPLETENESS OF INFORMATION

OTTAVIANI S.p.A. guarantees proper information activity towards collaborators, personnel,
and any other external subject that interacts with the undersigned company in relation to events
significant to company life. Financial data, company communications, and any other information that
this company provides to third parties meet the requirements of truthfulness, accuracy, and
completeness. For collaborators to whom OTTAVIANI S.p.A. has assigned specific consulting and
management tasks, in addition to the observance of norms, laws, and regulations, the company requires
the rigor demanded by the profession itself and, therefore, compliance with the relevant deontological principles.

5) CONFIDENTIALITY OF INFORMATION

OTTAVIANI S.p.A. has dedicated ample space to the security and confidentiality of company data
through the development of specific internal control programs regarding IT security; whereas regarding
legal and documentary aspects, the company conforms every processing operation to compliance with
the regulations. The attention paid to information security concerns all categories of data processed,
acquired, managed, organized, and stored. Furthermore, in the context of this topic, the company
emphasizes respect for intellectual property rights. It is forbidden to communicate and disclose
information, photos, or documents without having obtained the respective consent. No sensitive
information is disclosed. For every detail related to data processing, consult the “Legal Notes” text.
Upon termination of the relationship with OTTAVIANI S.p.A., it is forbidden to copy or retain
documents or other materials that are company property. “Company property” is defined as including
all improvements, ideas, products, graphic designs, and any other product created, designed, or
marketed through the site www.ottaviani.com or otherwise taken into consideration for its creation or
commercialization. Furthermore, this company has structured itself for better management of the
information system in order to optimize data processing and search times and to ensure its traceability.

6) PROHIBITION OF DISCRIMINATION AND EQUAL OPPORTUNITY

OTTAVIANI S.p.A. places the Person, whether they are a customer or a collaborator, at the center of its business
in their entirety. Consequently, there is a prohibition of discrimination based on social status, race, sex,
language, or religion. Respect for human dignity is a fundamental value that must be considered an
integral element of corporate conduct. Forms of discrimination and forms of human rights violations
through the encouragement of forced labor, child labor, and other types of abuse are not tolerated.
At the same time, the company does not implement behaviors or choices that violate the right to
equal opportunity.

7) PROTECTION OF COMPETITION

OTTAVIANI S.p.A. has always acted in the market respecting the rules of competition and
antitrust laws, refraining from taking actions to its own advantage that are contra legem.
The company has complied with the commercial agreements dictated by partners. Therefore, the company
bans any conduct aimed at hindering healthy and honest competitiveness. 8) CONFLICT OF INTEREST
OTTAVIANI S.p.A., in guaranteeing full transparency in its operations, undertakes to implement all
necessary measures to prevent situations of conflict of interest. This applies in the event that any
stakeholder pursues an interest different from the company mission or personally benefits from
the company's business opportunities. Every service is aimed at avoiding discriminatory behavior towards
others, and situations tending to create a conflict of interest must be avoided as they are harmful to the work
and the company itself. This company protects and guarantees the confidentiality of the personal
common and sensitive information of workers and issues periodic communications for correct and
transparent data processing.

9) GIFTS AND GRATUITIES

OTTAVIANI S.p.A. may provide gifts to existing and new customers (including those who have been
referred by others) as part of marketing plans carried out during the year.

10) RELATIONSHIP WITH CUSTOMERS

The Customer, like Human Resources, is a fundamental asset for this company, for whom policies
of continuous improvement in the quality and professionalism of the service offered must be activated.
OTTAVIANI S.p.A. always engages with the customer, believing that having an attitude open to
welcoming advice and criticism plays an important role in the growth of the company; obviously, all
this makes sense and is functional if the observations, even if negative, are expressed with a
constructive will and not out of a pure spirit of contradiction. It is fundamental that personnel adopt
a style of conduct towards the customer based on respect for the person, civil manners, kindness,
and professionalism. The company undertakes to make its method of communication with customers
clear and understandable by resorting to the use of various forms such as brochures and event
organization. All customer behavior aimed at theft, deception, and offense is prohibited.

11) RELATIONSHIP WITH SUPPLIERS

Relationships with suppliers and commercial partners are based on the search for the right
competitive balance. Such relationships are conducted with a spirit of loyalty and professional
integrity. The policies established by the commercial rules of the “supplier companies” are respected
by the company. OTTAVIANI S.p.A. intends to maintain an open dialogue with suppliers in line with
good business practices, even in the event of problematic situations. Following the same line of
conduct drawn up for personnel and customers, the company believes it is important to adopt a spirit
of cooperation with each supplier or commercial partner in order to pursue together the common
objective represented by customer satisfaction in terms of quality, cost, and delivery times.

12) ACCOUNTING TRANSPARENCY

Accounting activity is carried out in compliance with the rules established by our legal system
and, in the case of relations with foreign countries, in compliance with the relevant tax laws. The
management of the accounting part is entrusted to specifically appointed subjects with the support of
external professionals. Every accounting operation carried out and recorded is accompanied by the
corresponding supporting documentation, facilitating the control phase, the traceability of activities,
and highlighting the responsibilities of each operator. The use of company funds for illegal or
improper purposes is strictly prohibited and severely punished. OTTAVIANI S.p.A. respects
anti-money laundering regulations and prevents the commission of operations that are potentially
dangerous or otherwise not in compliance with what has been issued in the fiscal and tax spheres.

13) IT SECURITY

OTTAVIANI S.p.A. is a cutting-edge company that pursues improvement policies also from a
technological perspective. Consequently, this company is sensitive to the risks associated with the
ever-increasing use of information technology; therefore, the owner has already introduced
protection measures, but above all, a particular policy of constant control has been defined aimed at
guaranteeing the continuity of work and the integrity of information.

14) PROTECTION OF MINORS

OTTAVIANI S.p.A., within the scope of its marketing and e-commerce policies, protects the rights
of minors online through controls aimed at preventing unauthorized and reckless purchases.