Foreword Ferretti S.r.l. originates from Ferretti S.p.a., which has operated in the civil and infrastructure sector since 1903. Over the years, the Company has acquired high levels of organizational and technological quality in the fields of building, industrial, and refractory construction, building and refractory maintenance, and civil renovations. Ferretti S.r.l. operates in the field of building and industrial construction for public and private use. Specifically, the Company carries out the following activities:

Industrial building construction Refractory construction Building and refractory maintenance Civil renovations Civil works and large infrastructures Environmental remediation.

The Company employs internal resources with high professionalism and is characterized by a conscious management that, as a corporate policy, has always pursued the logic of corporate growth and the reinvestment of profits in the Company. Ferretti S.r.l. has a certified corporate management system in compliance with the UNI EN ISO 9001 standard.

The Company is committed to promoting the application of ethical principles to its activities. The focus is on promoting ethical conduct, which is materialized in the establishment and drafting of this document. The Code of Ethics is a set of principles and guidelines drafted by the Company's top management to guide the behavior of company personnel and also, where possible, of those with whom the Company comes into contact in every phase of work life, pursuing the objectives of efficiency and seriousness of ethical conduct. Through the adoption of the Code of Ethics, the Company has established a set of rules for:

• behavior in relations with external stakeholders, collaborators, the market, and the environment, to which the Company conforms its internal and external activities, requiring compliance from all collaborators, consultants, and, as far as applicable, external stakeholders;
• organization and management of the Company, aimed at creating an efficient and effective system for planning, executing, and controlling activities to ensure constant respect for the rules of conduct and to prevent their violation by any subject operating for the Company.

The provisions of the Code of Ethics and (limited to the applicable aspects) of the Crime Prevention Model are explicitly extended to the Company's personnel seconded to operate within controlled or associated companies, including companies established for the unified, total, or partial execution of acquired works. In drafting the Code of Ethics, the Company takes into account the Guidelines provided by the trade association ANCE for the creation of organization, management, and control models to be implemented regarding the prevention of crimes referred to in Legislative Decree no. 231 of June 8, 2001, on the administrative liability of companies. These Guidelines provide for and consider the code of ethics as the basis among the most relevant components of the control system, and recommend that the components of the control system and its recipients are informed of the principles contained and to be pursued continuously. This Code of Ethics is therefore an integral part of the organizational model and control system adopted by the Company for business management, which is therefore disseminated to all employees and integrates respect for civil and criminal laws, the reference laws for corporate activity, and the internal rules defined by the management system and internal regulations. All employees are required to respect this Code of Ethics, which has also been drafted with reference to the respect for national collective bargaining. The general concepts to be considered as fundamental principles are reported below.

1.1. This Code is addressed to the corporate bodies and their members, employees, temporary workers, consultants and collaborators in any capacity, agents, prosecutors, any other person who may act in the name and on behalf of the Company and, in general, to all those with whom the Company comes into contact in the course of its activities (hereinafter the "Recipients").

1.2. The Recipients, in carrying out their activities, adopt the principles of the Code of Ethics, inspired by values of impartiality, fairness, and transparency, and respecting the current legislation.

2.1 Compliance with the rules of the Code must be considered an essential part of the contractual obligations of the Company's employees, managers, and directors pursuant to and for the purposes of articles 2104, 2105, and 2106 of the Civil Code. Art. 2104, titled "Diligence of the employee," states: "The employee must use the diligence required by the nature of the service due, by the interest of the company, and by the superior interest of the national production. He must also observe the provisions for the execution and for the discipline of the work given by the employer and by the collaborators of the latter from whom he hierarchically depends." Art. 2105, titled "Duty of Loyalty," states: "The employee must not engage in business, for his own account or for third parties, in competition with the employer, nor disclose information concerning the organization and production methods of the company, nor use it in such a way as to cause it harm."

2.2 The Company evaluates, from a disciplinary point of view, in accordance with the law, behaviors contrary to the principles sanctioned in the Code of Ethics by applying, in the exercise of its entrepreneurial power, the sanctions that the different gravity of the facts may justify. Art. 2106, titled "Disciplinary sanctions," states: "The failure to observe the provisions contained in the two preceding articles may lead to the application of disciplinary sanctions, according to the seriousness of the infraction."

2.3 The serious and persistent violation of the rules of this Code of Ethics damages the relationship of trust established with the Company and may lead to disciplinary actions and compensation for damages, without prejudice, for employees, to compliance with the procedures provided for by art. 7 of Law no. 300/1970 (Workers' Statute) and by collective labor agreements.

2.4 Compliance with the rules of the Code of Ethics must be considered an essential part of the contractual obligations with the recipients.

2.5 Any behavior by collaborators who have relationships with the Company, in contrast with the rules set out in the Code of Ethics, may lead to (as provided for by specific contractual clauses included in letters of appointment, agreements, and contracts) the immediate termination of the contractual relationship, in addition to any request for compensation by the Company, should such behavior cause concrete damage to the Company.

3.1. The Recipients act loyally, in good faith, with diligence, efficiency, and fairness, basing their conduct on cooperation and mutual collaboration, in compliance with internal procedures. The activity of each individual is inspired by the will to increase their skills and improve their professionalism.

3.2. All activities carried out on behalf of the Company are aimed exclusively at satisfying the interests of the Company itself. Therefore, any situations of conflict between personal interest and that of the Company must be avoided or, at least, preventively communicated to the Sole Director.

3.3. In business relations with third parties, donations, benefits (both direct and indirect), gifts, acts of courtesy, and hospitality are prohibited, unless they are of such a nature and value that they cannot be interpreted as aimed at obtaining favorable treatment and, in any case, do not compromise the image of the Company.

4.1 The Company believes in free and fair competition and aligns its actions to achieve competitive results that reward ability, experience, and efficiency.

4.2. All actions, operations, and behaviors carried out by each of the Recipients, in the performance of their function or assignment, are inspired by fairness and legitimacy in both formal and substantial aspects and by the protection of the Company, according to current regulations and internal procedures.

4.3. Recipients do not use for personal purposes information, assets, and equipment at their disposal in the performance of their function or assignment.

4.4. The Company and its collaborators must maintain correct behavior in business of interest to the Company and in relations with the Public Administration and with private Clients. Any action aimed at altering the conditions of fair competition is contrary to the Company's Policy and is forbidden to any subject acting on its behalf.

4.5. In no case can the pursuit of the Company's interest justify conduct by the top management, employees, or collaborators that is not respectful of the laws in force and compliant with the rules of this Code.

4.6. In any external communication, the information regarding the Company and its activities must be truthful, clear, and verifiable.

5.1 The preparation of the financial statements and any other type of accounting documentation complies with the laws and regulations in force, adopts the most advanced accounting practices and principles, and is inspired by the principle of transparency in relations with stakeholders, faithfully representing the management facts according to criteria of clarity, truthfulness, and correctness in compliance with internal procedures.

6.1. The choice of suppliers is inspired by principles of objectivity, competence, cost-effectiveness, transparency, and fairness, in compliance with the relative internal procedures derived from the company management system in use and certified by a Third-Party Certification Body.

6.2. Suppliers are required to:

• comply with applicable laws and regulations;
• conform to the principles of this Code of Ethics;
• respect the current legislation on labor, with particular attention to child labor and to the provisions of the law on health and safety;
• ensure appropriate remuneration levels for dependent personnel;
• not support in any way, either directly or indirectly, terrorist associations;
• guarantee respect for human and workers' rights;
• respect the contractual requirements defined between the parties and in compliance with the legislative requirements and the company management system.

7.1. Relations with customers are based on the full satisfaction of their needs with the aim of creating a solid relationship inspired by principles of fairness, honesty, efficiency, and professionalism, and clear contractual relationships defined by precise procedures that define tasks, responsibilities, and skills required to obtain the result of greater satisfaction for the parties involved.

7.2 In participating in tenders, the Company carefully evaluates the congruity and feasibility of the requested services with particular regard to the technical and economic conditions, safety, and environmental aspects, pointing out any anomalies as promptly as possible. The formulation of the offers must be such as to allow compliance with adequate quality standards, appropriate remuneration levels for dependent personnel, and current safety and environmental protection measures.

7.3 The company resorts to litigation only when its legitimate claims are not met with due satisfaction by the other party.

7.4 In conducting any negotiation, situations in which the parties involved in the transactions are or may appear to be in a conflict of interest must always be avoided.

8.1. The Company's relations with the Public Administration, public officials, or persons in charge of a public service must be inspired by the strictest observance of the applicable legal provisions and may not in any way compromise the integrity or reputation of the Company.

8.2. In particular, relations with public representatives or employees must comply with the principles and provisions dictated by the Prime Ministerial Decree of November 28, 2000 (Code of Conduct for Public Employees).

8.3. The assumption of commitments and the management of relations with the aforementioned subjects are reserved exclusively for the corporate functions designated for this purpose and for the authorized personnel, in full compliance with internal procedures and the principle of transparency.

8.4. In the context of relations with representatives, officials, or employees of public administrations, Recipients must refrain from:

• offering, including through an intermediary (e.g., their family members or subjects connected to them in any way), goods, money, or other benefits;
• seeking or establishing personal relationships of favor, influence, or interference suitable to condition, directly or indirectly, the outcome of the relationship.

8.5. In particular, towards representatives, officials, or employees of public administrations, no form of gift is permitted that may even appear to exceed normal commercial or courtesy practices, or is in any case aimed at acquiring favorable treatment in the conduct of any activity.

8.6 It is forbidden to make, induce, or favor false statements to public authorities.

9.1 The Company does not provide contributions, advantages, or other benefits, direct or indirect, in any form, to parties, movements, committees, and political and trade union organizations, nor to their representatives and candidates, except in compliance with applicable regulations.

10.1. The Company does not make illicit payments of any kind and bases all its financial activities on the principle of absolute traceability and transparency.

10.2. Lawful and duly authorized payments must be made promptly, on the correct due dates, and directly to the intended recipients.

10.3. The Company avoids discrimination in payments, favoring some creditors over others.

11.1. The Company is committed to protecting the environment as a primary asset; to this end, production activities are managed in compliance with current legislation on environmental protection and pollution prevention.

11.2. The Company is convinced that the full compatibility of its activities with the territory and the surrounding environment is a primary condition for both the acceptability of its activities and the achievement of its development objectives. To this end, the Company carries out or ensures that all investigations required by current legislation are carried out to verify the possible environmental risks arising from the intervention and to prevent damage.

11.3. This responsibility is borne equally by directors, managers, and all employees and collaborators of the Company.

11.4. The Company is committed to disseminating and consolidating a culture of environmental protection and pollution prevention among all its directors, managers, employees, collaborators, and suppliers, developing risk awareness and promoting responsible behavior on the part of all collaborators.

12.1. The Company promotes a culture of safety in the workplace, encourages responsible behavior by employees, and provides adequate tools for preventing workplace injuries to safeguard the health of its personnel.

12.2. All activities of the Company and of the individual employee must be oriented towards respect and protection of safety in the workplace, scrupulous compliance with the rules and obligations deriving from the reference legislation on safety, as well as compliance with all measures required by procedures and internal regulations.

12.3. Recipients, within the scope of their duties, participate in the process of risk prevention towards themselves, their colleagues, and third parties.

12.4. In the conduct of its business activities, the Company attributes significant value to and implements measures that respect the following principles for the protection of workers' health and safety:

• avoid or reduce to the maximum extent possible the risks that can undermine the health and safety of workers in the workplace;
• take into account the degree of technical evolution in order to make the workplace as healthy and safe as possible;
• replace what is dangerous with what is not dangerous or is less dangerous;
• plan prevention, taking into consideration the technical aspects, the organization of work, working conditions, and the influence of environmental factors;
• give priority to collective protection measures over individual protection measures;
• provide adequate instructions to workers.

13.1. The worker must take care of his own safety and health and that of other persons present at the workplace, who may be affected by his actions or omissions, in accordance with his training, instructions, and the means provided by the employer, observing the provisions and instructions given by the employer, managers, and supervisors, for the protection of both himself and others (as established by Art. 20 of Legislative Decree 81/2008).

14.1. The Company guarantees the freedom of association of workers and recognizes the right to collective bargaining.

14.2. The Company rejects all discrimination based on age, sex, sexuality, health status, race, nationality, political opinions, and religious beliefs; it repudiates all forms of discrimination in hiring policies and in the management of human resources.

14.3. In the case of hiring persons from third countries, the Company preventively verifies compliance with the rules of residence and checks that the conditions of regularity persist for the entire duration of employment.

14.4. The Company undertakes to prevent any form of mobbing and exploitation of labor, both direct and indirect, and to recognize on merit the determining criteria for any salary and career developments of each individual worker.

15.1. Human resources are an indispensable element for the existence, development, and success of any enterprise.

15.2. All personnel are hired by the Company with a regular employment contract; the employment relationship is carried out in compliance with the collective contractual regulations of the sector and the applicable social security, tax, and insurance regulations.

15.3. The Company pays particular attention to the enhancement, protection, and development of the skills and competencies of all its employees, so that they can express their potential and professionalism to the fullest, and consequently, contribute to the achievement of the company's objectives in compliance with the commitments of social and environmental responsibility defined by the top management.

16.1 Each recipient is responsible for the protection and conservation of the company's assets, both tangible and intangible, entrusted to them for the performance of their duties, as well as for their proper use in accordance with company purposes and current legislation.

17.1. The employee may under no circumstances accept or give gifts of money.

17.2. The employee must not accept or give, even on the occasion of festivities, gifts or other benefits related to their professional activities unless they are of modest value and not convertible into cash.

17.3. The employee who, in the exercise or performance of the duties to which they are assigned, receives gifts or other benefits is required to promptly notify the Top Management (Sole Director), who will assess their appropriateness (consulting, if necessary, with the Supervisory Body), and may eventually request the return of the gift.

17.4. The employee may not entertain private commercial relations with suppliers used by the company, unless preventively authorized by the top management.

17.5. Recipients shall refrain from practices not permitted by law, by commercial custom, or by any ethical codes of the companies or entities with which they have relations.

18.1. Regarding the use of IT systems, every employee of the Company is responsible for the security of the systems used and is subject to the regulatory provisions, the conditions of the license agreements, and the company regulations in force.

18.2. Without prejudice to the provisions of civil and criminal laws, the improper use of company assets and resources, including the use of network connections for purposes other than those related to the employment relationship, falls within this scope.

18.3. Every employee is also required to make the necessary effort to prevent the possible commission of crimes through the use of IT tools.

19.1. The Company undertakes to ensure compliance with the rules of this code also through the establishment of a Supervisory Body with tasks of supervision and monitoring regarding the implementation of the Code of Ethics.

19.2. This Body will specifically be responsible for:

• constantly monitoring the application of the Code of Ethics by the interested parties, including through the reception of any reports and suggestions;
• reporting any significant violations of the Code of Ethics;
• expressing binding opinions on any revision of the Code of Ethics or of the most relevant company policies and procedures, in order to ensure their consistency with the Code itself.

20.1 In compliance with current legislation and in the context of planning and managing company activities aimed at efficiency, fairness, transparency, and quality, the Company adopts organizational and management measures suitable to prevent illicit or otherwise contrary behaviors to the rules of this Code by any person acting for the Company.

2.2 Due to the articulation of activities and its own organizational structure, the Company adopts a system of delegation of powers and functions, providing in explicit and specific terms for the assignment of tasks only to persons with suitable capacity and competence.

20.3 In relation to its own size and the extent of delegated powers, the Company adopts and implements organizational and management models that provide for suitable measures to ensure the conduct of activities in compliance with the law and the rules of conduct of this Code, and to discover and promptly eliminate risk situations.

21.1 The Company adopts specific methods for controlling the conformity of the behaviors of anyone acting for the Company or within its scope, with the provisions of current legislation and the rules of conduct of this Code.

21.2 The application and respect of this Code of Ethics are monitored by the Supervisory Body, which also promotes initiatives for the dissemination of knowledge and understanding of the same.

22.1. All employees are required to report promptly and confidentially to the Supervisory Body, which undertakes to ensure the secrecy of the identity of the reporters without prejudice to legal obligations, any information they become aware of in the performance of their work activities, regarding violations of legal norms, the Code of Ethics, or other company provisions that may, in any capacity, involve or harm the Company.

22.2. Reports, like any other violation of the Code detected following other assessment activities, are promptly evaluated by the Supervisory Body for the adoption of any sanctioning measures. No provision or discrimination should be linked to the person who reported the violation, even if it turns out to be unfounded. The highest level of confidentiality must be guaranteed to the people involved.

22.3. It is the right/duty of each Recipient to turn to their superiors or to the Supervisory Body in case of need or request for clarification on the methods of application of the rules of this Code of Ethics.

23.1 The Company undertakes to promote and ensure adequate knowledge of the Code of Ethics by disseminating it to the interested parties through specific and adequate communication activities.

23.2 So that anyone can conform their behavior to what is described herein, the Company will ensure an adequate training program and continuous awareness of the values and rules contained in this Code of Ethics.

24.1 The observance by the Company's employees of the rules of the Code must be considered an essential part of the contractual obligations pursuant to art. 2104c.c.

24.2 The violation of the rules of this Code of Ethics by the employee constitutes a breach of the primary obligations of the employment relationship or a disciplinary offense and may lead to the disciplinary sanctions provided for by the current C.C.N.L. (National Collective Labor Agreement) for the sector and in application of the company's disciplinary system, as well as, according to the gravity, to any legal, civil, or criminal actions.

25.1 The issuance and any subsequent revision of this Code of Ethics are approved by the Sole Director and are promptly disseminated to the Recipients.

25.2 The proposal for revision is formulated in particular by the Supervisory Body or by the Top Management, taking into account any contributions and/or reports of shortcomings from the Recipients, with reference to the principles and contents of this Code of Ethics.