CODE OF ETHICS AND MODEL 231

The company Cellularline S.p.A. (previously the single shareholder company Cellular Italia S.p.A.) adopted the “Organisation and management model in accordance with Italian Legislative Decree 231/2001” (hereinafter the “Model”) on 3 March 2017 and appointed the Supervisory Board (hereinafter “SB”) provided for by the same legislation. Italian Legislative Decree 231/2001 introduced corporate administrative liability for specific offences to be ascertained through criminal proceedings.
The “Organisation and management model in accordance with Italian Legislative Decree 231/2001”, along with the Supervisory Board that guarantees compliance with and updating of the same, are the tools that the same legislation makes available to the company for the purpose of preventing offences being committed, minimising the risk and therefore relieving it of administrative liability in criminal proceedings.
For the purpose of performing its preventive function, the Model contains a set of behavioural protocols and a Code of Ethics which, in relation to the part of interest, anyone establishing contractual relationships with Cellularline S.p.A. (previously the single-member company Cellular Italia S.p.A.) is obliged to be familiar and comply with.