Health and Safety & Ethic Code

231 MODEL

The Legislative Decree No. 231/2001, regarding the “Discipline for the administrative liability of the legal entities, businesses and associations, including bodies without legal entities”, introduced for the first time into Italian law, the responsibility of the bodies in penal for a number of cases of offenses committed in the interests of, or to the advantage of the same, by persons performing representative, administrative or managerial functions of said bodies or of one of their organizational units with financial and functional autonomy, or by persons exerting, de facto or otherwise, the management and control of said bodies (the so-called apical subjects), as well as by persons subjected to the management or the supervision of one of the bodies indicated above (the so-called subjects under others’ management).

In order to assure, as much as possible, the prevention of the offenses stated by the Decree, the Board of Directors of OLSA S.p.A. adopted, on March 6th 2012, a new Model for organization, management and control (so called 231 Model).

The 231 Model is a part of a wider corporate governance policy of OLSA S.p.A., which takes care of the corporate management’s ethical principles, as represented by the Code of Ethics (also based on the Decree).

A Compliance Committee has been charged with the 231 Model’s management.

For any violation of the 231 Model or the Code of Ethics, or any other information the Compliance Committee can be reached at its email address organismodivigilanza@olsa.com