This Code of Ethics expresses the principles, values and rules of conduct inherent in the actions of the VDR INSTALLATION GROUP LTD (hereinafter also “ VDR Group ” or “Company”).

The contents of this document are continuously updated and developed to adapt them to the continuous transformation of the environment in which VDR Group operates, so as to enrich the concept of Ethics spread and acquired by the Group.

This Code of Ethics constitutes a fundamental and integral part of the 231 Organizational Model adopted by the VDR Group.

The Code of Ethics is inspired by the main laws, guidelines and regulations existing at a national and international level on the subject of corporate social responsibility, corporate governance, human rights and the environment.

The document also mentions the principles of corporate ethics and the rules of conduct aimed at preventing the commission, according to Maltese Law, of the crimes provided for by Legislative Decree.

This Code expresses the commitments and ethical responsibilities of the company in the context of the activities carried out towards customers and in the context of internal activities of the company with regard to all stakeholders including shareholders, employees and collaborators.

The Code therefore constitutes a set of principles whose observance by all those to whom it is addressed is of fundamental importance for the regular functioning, reliability of management and the image of the VDR Group.

This Code of Ethics, therefore, has been prepared with the aim of clearly defining the set of values that VDR Group recognizes, accepts and shares.

VDR Group ensures an information and awareness program on the provisions of this Code and on its application to the subjects to which it refers, so that all those who work for VDR Group can carry out their activities and/or their duties in accordance with constant and strict compliance with the principles and values contained in this Code.

“A company shaped on services to companies, to the community, to institutions:

innovative and reliable, dynamic and sustainable”

VALUES, RESPONSIBILITY, TOWARDS SOCIETY

We pursue results with respect for collaborators, customers and suppliers, creating

value and spreading the culture of work in the area in which we operate.

TOWARDS THE PEOPLE

We take care of employees and their safety. We value them

people who express passion in work, ethics, integrity and correctness.

TOWARDS THE ENVIRONMENT

We are committed to reducing the impact of our activities on the environment,

optimizing resources according to a sustainable growth model.

TOWARDS OUR HISTORY

We want to live up to our past, projecting our Group

into the future, guaranteeing continuity and development while respecting tradition.

This Code applies to all Group of VDR Companies, in any country and at any level of the organization.

The Code of Ethics is addressed to all members of the Board of Directors (President, CEOs, Councillors), managers, staff (employees and otherwise) and third parties (customers, suppliers) who carry out activities with and on behalf of VDR Group, whether employed by the Company or not, in all the countries in which it operates. The recipients of the provisions of the Code are required to observe the provisions contained therein and to adapt their behavior and actions to the principles expressed.

VDR Group undertakes:

• to adopt, by resolution of the Board of Directors, this Code of Ethics;
• to recall compliance with the provisions of this Code in all internal and external relationships established by it and to disseminate it as widely as possible;
• to provide a copy of this Code to all personnel.

To ensure that it is easily accessible and available to all recipients, the Code is translated into English and published On VDR‘s institutional website GROUP (www.vdrgroupmalta.com ) and on that of each company in the Group.

All VDR Group employees  are required to:

(1) know and comply with the laws, regulations, policies and procedures of the Group applicable to their work activity;

(2) immediately seek advice and guidance if in doubt about what action to take and encourage others to do the same;

(3) identify and report problems or potential violations regarding the issues covered by the Code of Ethics;

(4) not judge or retaliate in any way against individuals who report issues or violations or participate in an investigation.

If the Code and local legislation do not conflict, compliance with both is required. In the event that the laws and regulations in force in a particular jurisdiction are more permissive than those contained in this Code, the latter will prevail.

In case of doubt or inability to comply with local legislation without violating the Code or vice versa, all recipients of this document must immediately contact one of the persons or groups of persons listed below:

– your direct superior, the Group Internal Audit & Compliance function, the Legal and General Affairs Department, the Human Resources Department;

– for reports of violation or fraudulent circumvention of the principles and provisions of the Organization, Management and Control Model pursuant to Legislative Decree to the dedicated channels of the Supervisory Bodies.

Anyone who holds the role of Manager/Supervisor/Manager must set an example and therefore carry out their activities in compliance with the principles and behavioral rules contained in this Code, demonstrating with their actions to other collaborators that compliance with the Code constitutes a fundamental aspect of the own work, ensuring that everyone is aware that business results go hand in hand with respect for the principles of the Code.

For this reason, company management is expected to be able to adapt to the highest standards of ethical conduct and encourage knowledge of the ethical implications relating to work decisions.

Compliance with this Code of Ethics is the exclusive and personal responsibility of each employee. In case of transgression, employees cannot justify their lack of knowledge of this provision or their having acted on orders from higher level managers. The Code is an integral part of the contractual obligations of the subjects who have relationships with the Company and/or other companies of the Group, and in particular for employees (managers and otherwise), also pursuant to and for the purposes of Diligence of the Employee.

Those who violate the Code or current legislation or who behave in a manner contrary to the spirit of the Code are subject to consequences assessed and commensurate based on the type, severity of the violation committed and the role of the subject which may also include possible termination of the employment relationship or any other form of contract, in addition to compensation for any damages resulting from the violation, as well as the initiation of legal proceedings. Any violation of the Code will be assessed objectively and fairly by the competent bodies, who will apply the appropriate disciplinary sanctions.

The application of disciplinary sanctions is independent of the outcome of any criminal or civil proceedings, as the rules of conduct imposed by the Code are effective regardless of the crime and/or offense that any improper conduct may cause. No illicit or in any case behavior in violation of the provisions of this Code or even merely illegitimate or incorrect behavior can be justified or considered less serious, even if carried out in the interest or to the advantage of Group companies.

The relationships that each VDR company Group’s dealings with various subjects are based on standards of transparency, correctness, collaboration, fairness, loyalty and mutual respect.

Employees, regardless of the role and function performed, must carry out their activities in the interests of the Company, conforming to the behavioral rules contemplated in this Code. The information disseminated both inside and outside the Company must be characterized by truthfulness, accuracy and completeness. Constant compliance with these rules of conduct allows the implementation of the principle of transparency.

The Company ensures that all the subjects operating within it comply with the principles of correctness and loyalty in carrying out their functions, both internal and external, also for the purposes of maintaining the image of the Company and the relationship of trust established with the Customers, and more generally, with third parties.

Employees must carry out their duties with diligence and accuracy, in compliance with the directives given by direct managers, and in general, with company quality standards.

Competition and antitrust laws aim to prohibit unreasonable restrictions on trade and preserve competition.

Examples of competition and antitrust violations include price fixing, bid rigging, market or customer sharing, and limitations on production, sales, and services. The penalties for competition and antitrust violations are severe and individuals who commit violations can be punished severely up to and including imprisonment. Therefore agreements that result in violation of fair competition are strictly prohibited, as are commercial practices that may constitute a violation of antitrust laws. All employees must refrain from engaging in unfair behavior. In the context of fair competition, VDR Group undertakes not to knowingly violate the intellectual property rights of third parties.

VDR Group refrains from engaging in collusive and abusive behavior of a dominant position and undertakes to reject and bring to light all practices aimed at distorting or reducing free competition in the market.

VDR Group acts in full compliance with industrial and intellectual property rights, as well as laws, regulations and conventions, including within the EU and/or international context, to protect such rights.

In this regard, all Recipients must respect the legitimate industrial and intellectual property rights of third parties and refrain from unauthorized use of the aforementioned rights, in the awareness that violation of the same may have negative consequences for VDR Group.

In particular, the Recipients, in carrying out their activities, must refrain from any conduct that could constitute usurpation of industrial property rights, alteration or counterfeiting of trademarks and/or distinctive signs of industrial products, or of patents, industrial designs or models , both national and foreign, as well as refrain from importing, marketing or otherwise using or otherwise putting into circulation industrial products with counterfeit or altered or false trademarks and/or distinctive signs or created by usurping industrial property rights.

VDR Group does not tolerate any form of corruption, is committed to respecting the anti-corruption laws in force in all countries in which it operates and requires all its stakeholders to act with honesty and integrity at all times. All decisions and business choices made on behalf of VDR Group must correspond to your best interests and be in line with company values.

Collaborators, therefore, must avoid situations and/or activities that could lead to conflicts of interest with those of the Company, or that could interfere with their ability to make impartial decisions, in safeguarding the best interests of the same. Such activities can damage the Company financially, but even more significantly they can cause damage to its reputation.

Any situation that could give rise to an actual or potential conflict of interest must be disclosed and reported to the persons indicated in paragraph 2.

VDR Group undertakes to prevent the use of its economic-financial system for the purposes of money laundering and terrorist financing (or any other criminal activity) by its Customers, Suppliers, Employees and counter parties with which it interacts in the carrying out its activities. VDR Group verifies with the utmost diligence the information available on commercial counter parties, consultants and suppliers, in order to ascertain their respectability and the legitimacy of their activity before establishing any business relationship.

Collaborators are required to strictly observe the laws, company procedures and policies in any economic transaction, including intra-group ones, in which they are involved, ensuring full traceability of incoming and outgoing financial flows and full compliance with anti-money laundering laws.

Corporate Social Responsibility is how VDR Group intends to emphasize the social impact of its structures and activities, affirming the principles and values that guide the Group both in its internal processes and methods and in its interactions with other subjects.

VDR Group expresses its strong commitment to the principles of Corporate Social Responsibility as an element of integration of its policies and interrelationship with Customers, Suppliers and all interest groups with which it interacts. In this regard, VDR Group, faithful to the corporate objective of generating wealth and well-being for the community, adopts a business ethic that allows it to harmonize the creation of value with sustainable development which includes environmental protection, social cohesion and appropriate communication as its main objectives. .

All employees, in their respective functions, are required to enforce and ensure the correct functioning of internal controls. Internal controls mean all the controls necessary or useful to evaluate, manage and control the activities of VDR Group; the objective is to ensure compliance with this Code, the policies and procedures adopted by the Group.

These controls aim to protect company assets, manage operations effectively, provide accurate and complete accounting information and prevent illegal behavior. The Management is primarily responsible for the creation of an effective internal control system, but employees at all levels of the organization have the responsibility to adhere to the established controls and to identify and report any perceived weaknesses or dysfunctions for the correct functioning of the internal controls, making use of the Internal Audit function of Group, which operates with independence and objectivity in line with international professional standards.

The management of financial resources takes place by operating according to the principles of transparency, verifiability, coherence and congruity. Accounting transparency is based on the existence, accuracy and completeness of the basic information for the relevant accounting records. Each director, employee, collaborator and service provider is required to ensure that management facts are correctly and promptly represented in the accounting. For each operation, adequate supporting documentation of the activity carried out must be kept in the records, so as to allow (i) easy recording in the accounting, (ii) identification of the different levels of responsibility, (iii) the accurate reconstruction of the operation, also to reduce the probability of interpretative errors.VDR Group is committed to training all staff responsible for creating and recording accounting operations.

Acts of commercial courtesy towards third parties, as well as the receipt of the same, are permitted, provided they are of modest value, and in any case such as not to compromise the integrity and reputation and not to influence the autonomy of judgment of the recipient. All acts aimed at corrupt practices of any kind towards third parties, both private and public, are expressly prohibited, as they are absolutely contrary to the Group’s culture.

Collaborators are prohibited from accepting or soliciting promises or payments of money or goods or benefits, pressure or services of any kind which may be aimed at promoting the hiring of a Collaborator or his/her transfer or promotion.

It is important that these are directly linked to a legitimate business purpose and that the offer or acceptance of them is strictly limited in terms of value and frequency and does not give the impression of being unlawful. Do not offer gifts or hospitality if you know that the recipient’s code of conduct prohibits accepting them.

VDR Group ensures the confidentiality of the information and the protection of the information acquired as a result of the work carried out, in order to prevent it from being used for its own interests so as to gain undue profit, or for purposes contrary to the law or such as to cause damage to society.

By way of example and without limitation, information relating to: products, technical, technological and commercial knowledge of the Company, work projects, including commercial, management, industrial and strategic plans, data relating to know-how and technological processes is considered confidential. , financial operations, operational strategies, investment and disinvestment strategies, operational results, personal data of Collaborators and lists of Customers and commercial partners, information relating to present and future activities, including news not yet released even if subject to announcements soon to be disclosed , meeting minutes, procedures, regulations, contracts, organizational charts, information systems.

All notes, memos, minutes and writings (including copies) generated within the Companies, all information and other material, obtained by each of the Recipients according to their position within VDR Group or by virtue of having a business relationship with it, are and remain the exclusive property of VDR Group with which the Recipients have a working or business relationship.

All Recipients are obliged to return the aforementioned documents, information and materials to the Company upon request of the latter and, in any case, upon termination of the working or business relationship with the same.

Confidential information of VDR Group should never be shared with anyone who does not need to know such information to perform work or service for the VDR Group. As a general rule, information is confidential they can only be shared with authorized people. Even within Group companies, confidential information should only be shared when necessary. Personnel must follow all security procedures and avoid cases that could lead to the loss, misuse or theft of VDR Group information.  Also other information from third parties with which VDR Group does business or interacts must be respected.

The obligation of confidentiality regarding information regarding the technical, technological and commercial knowledge of the Company, as well as other non-public information relating to the same, must remain even after the termination of the employment relationship.

The Recipients, therefore, in processing such data and information, undertake to protect the information acquired and/or generated and to avoid any improper and/or unauthorized use. Failure to comply with the confidentiality obligation will be considered a serious violation of this Code.

As part of carrying out its activity, VDR Group collects a significant amount of personal data and confidential information, which it undertakes to process in compliance with all laws in force in its jurisdiction and the best

practices applied regarding confidentiality and privacy.

The Company, which has already complied with the provisions of the previous reference laws  regarding the protection of personal data, currently operates in compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation, also known as “GDPR”). The Company respects the rights recognized to interested parties by the Privacy Legislation, be they collaborators, customers or suppliers of the Company, providing them with complete and updated information on the processing of data – both common and possibly falling within the “special categories” – acquired by the Company or which will be acquired and/or processed in the course of its activity, having identified the appropriate legal bases with respect to the various treatments, and applying the principles imposed by the Privacy Legislation (including, the principles of lawfulness, correctness and transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality, accountability).

VDR Group undertakes to ensure that the personal information acquired is appropriately protected, according to the terms established by the privacy legislation, avoiding improper or unauthorized use, to protect the dignity, image and confidentiality of each subject, whether internal or external to the Group. The processing of personal information occurs lawfully and correctly.

Personal information is collected and stored only if it is necessary for certain explicit and legitimate purposes.

Data will be stored exclusively for a period of time not exceeding that necessary for the aforementioned purposes.

For greater protection and transparency towards interested parties, the Company, in its capacity as data controller, has defined a system of internal appointments in order to entrust specific tasks on the processing of personal data to qualified internal figures.

In implementing the rule referred to in art. 29 of the GDPR, VDR Group has formally delivered to all those authorized to process the specific instructions for the type of activity that each of them will have to carry out on the data.

The Company is committed to protecting, disseminating and consolidating a culture of safety and health in the workplace, developing awareness of risks and promoting responsible behavior by all employees and collaborators.

The Company promotes the culture of safety in the workplace also through information and training meetings aimed at staff. The Company’s activities must be carried out in full compliance with the OHSAS 18001 and the Health and Safety principles contained in the Quality, Health, Safety and Environment Policy in order to integrate the principles of sustainable development into all its activities worldwide .

“Zero injuries” is VDR Group’s main priority on the subject of safety in all its environments, both internal and external. It pursues this objective by committing itself to ensuring the safety of all its offices and external construction sites in accordance with the highest applicable standards and promoting awareness of this primary objective in all its Employees.VDR Group has chosen as its priority

absolute to adhere to the OHSAS 18001, Safety certification system, thus committing to reducing exposure to risk in the workplace and improving the Safety Management System and its performance, through consultation, participation and training of the entire staff.

Regardless of the place of work (plant/offices/territory), each employee must actively commit to protecting their health and that of others, be they employees, visitors, suppliers, customers or members of the communities in which they operate.

VDR Group is committed to the protection of natural resources and the environment. The Group considers the environment a primary value and manages its corporate activities in full compliance with current environmental regulations.

To this end, each recipient of the Code of Ethics must operate in line with the following principles:

• implement all necessary actions in order to ensure compliance with and adaptation to current regulatory provisions;
• promote a culture of respect for the environment and ensure that staff are constantly updated on legislative and regulatory developments in environmental matters;
• integrate care for environmental aspects in the activities carried out and raise staff awareness of environmental issues, in order to achieve high standards of professionalism;
• monitor technological progress and evaluate their implementation if they are able to guarantee greater environmental protection.

VDR Group has chosen to join the environmental certification system, committing itself to the development of a sustainable business, preventing pollution and minimizing the environmental impact of its activities, using natural resources and energy in the most efficient way.

VDR Group communicates its QHSE policy throughout the organization and trains its employees in the correct use of Quality, Health, Safety and Environment management systems.

The QHSE companies refrain from carrying out activities that could constitute a violation of the regulations established to protect the heritage having cultural or landscape relevance and/or interest.

If QHSE were to promote or participate in financing or capital investment activities regarding artistic works or art collections or renovation of prestigious assets, it will pay attention to the profiles of merit functional to preventing actions of money laundering or receiving stolen goods, or violation of regulations binding.

Company activities, if they impact an environmental context subject to valuable landscape, cultural or artistic restrictions, must be conducted in full compliance with the relevant technical standards (Cultural Heritage and Landscape Code).

VDR Group considers respect for employees and their personal growth as an inviolable principle, promotes a healthy and safe working environment, prevents discrimination and harassment in working relationships.

The Code of Ethics is an integral and substantial part of the employment contract of each collaborator and therefore VDR Group requires all collaborators to strictly observe the provisions of the Code of Ethics. Any violation of the provisions of the same is therefore treated firmly with the consequent adoption of adequate sanctioning measures.

The Company is committed to offering equal opportunities in work and professional advancement to all Collaborators, creating initiatives to increase their skills and abilities.

Collaborators must be treated, for all aspects of the employment relationship, such as hiring, training, remuneration, promotions, transfers and termination of the relationship itself, in a manner consistent with their ability to satisfy the requirements of the job , avoiding any form of discrimination and, in particular, discrimination based on race, sex, age, nationality, religion, personal beliefs, political opinions, state of health.

VDR Group is committed to protecting the psycho-physical well-being of its people, protecting the physical and moral integrity of its employees and collaborators, ensuring working conditions that respect individual dignity, in full compliance with

individual and collective contracts, the Workers’ Statute as well as the current legislation on the safety and health of workers and the laws governing human rights and work. The Company promotes the elimination of all forms of discrimination, illegal, forced labor, slavery or servitude, in particular child labor.

Discrimination, illegal, forced labor, slavery and servitude, in particular child labor at VDR Group suppliers, contractors and associated persons will not be tolerated.

The VDR Group Companies ensure that no acts of violence, psychological coercion or surveillance are carried out, as well as any attitude or behavior that undermines the dignity of the person.

In the management of employment relationships, it is forbidden to pay wages in a manner that differs from the national or territorial collective agreements stipulated by the most representative trade union organizations at a national level and in any case it is forbidden to pay wages that are disproportionate to the quantity and quality of the work performed.

The VDR Group Companies undertake to respect the legislation relating to working hours, rest periods, weekly rest, compulsory leave, holidays, with the exception of justified, traceable exceptions based on agreements reached with trade unions to be communicated with immediacy to the B.O.D.

The VDR Group Companies also ensure that behaviors aimed at inducing or forcing, directly or indirectly, employees to adopt conduct in violation of this Code of Ethics or internal regulations are not implemented.

Anyone has the right to apply for a position within the VDR Group or be considered for a new position in compliance with the required requirements and merit criteria, without discrimination.

Hiring takes place with a regular employment contract and in full compliance with the current and applicable legislation regarding working hours, rest periods,

weekly rest, compulsory leave, holidays, and the provisions contained in the Collective Labor Agreement.

When the collaboration begins, the employee must receive comprehensive information on the Contract, with particular reference to the characteristics of the tasks to be carried out and the company function to which he is assigned, as well as on the remuneration aspects, principles and rules contained in the Code of Ethics.

The evaluation of individual performance must take into account not only “what” was achieved but also “how” the results were achieved, rewarding respect and conformity to the behaviors and principles adopted by VDR Group.

VDR Group in relations with customers – private entities – adopts behaviors inspired by principles of transparency, reliability, responsibility and quality. These relationships must be based on principles of mutual transparency, respect for market rules, through reliable and correct behaviour, guaranteeing complete and accurate information on the products and services offered.

Each Employee must towards the Customer:

• behave in compliance with the principles of mutual competition, good faith and timely fulfillment of contractual obligations;
• scrupulously observe the provisions of this Code of Ethics and the internal procedures relating to the management of relationships with

the Customers, as well as all contractual provisions defined according to current legislation;

• ensure the quality and reliability of the services offered;
• avoid any initiative that could lead to unjustified favoritism, giving one customer an advantage over others;
• avoid receiving money or other benefits or benefits, even if of modest value, for the execution, certification or adoption of an act contrary to official duties;
• avoid receiving gifts, freebies or other advantages, even if of modest value, if the donation aims to obtain illicit benefits.

VDR Group, in its relations with Suppliers, is inspired by the principles of absolute honesty, loyalty, good faith, correctness, impartiality, transparency and free competition.

Suppliers must observe and respect the values and principles expressed in this Code. VDR Group is committed to guaranteeing fair opportunities to any potential Supplier, in compliance with the principles of transparency, with the aim of developing relationships of collaboration and cooperation through a process of constant communication for a mutual partnership. The selection of Suppliers must be based on the evaluation of the quality of services and products, as well as their competitiveness, as well as on the congruence of the professional and technical performance with the specifications, and on aspects of social responsibility.

Each Employee must:

• relate to the Group’s suppliers with transparency and fairness, guaranteeing fair opportunities;
• observe and respect, in supply relationships, the legal and regulatory provisions in force as well as those issued on the matter by the Company;
• scrupulously observe the set of rules established by the regulations in force as well as by the relevant organizational procedures

supplier selection;

• observe the contractual conditions envisaged, correctly managing the relationship with the supplier;
• avoid any initiative that could lead to unjustified favouritism, giving one supplier an advantage over others;
• avoid receiving money or other utility or benefit, even if of modest value, for the execution, certification or adoption of a

act contrary to official duties;

• avoid receiving gifts, freebies or other advantages, even if of modest value, if the donation aims to obtain illicit benefits.

Sharing the Code of Ethics represents a necessary prerequisite for establishing and maintaining supply relationships.

Each Group Supplier must respect the values and principles expressed in this Code, taking into account that failure to comply with the provisions contained therein may put an end to the supply relationship.

Relationships with these subjects must be characterized by legality and transparency and must be managed exclusively by company subjects expressly delegated and authorized for this purpose.

It is forbidden to make any type of payment, offer or receive any benefit of value in the context of relations with the PA for the purpose of obtaining or maintaining an assignment or any other advantage in favor of VDR Group.

In relations with officials/employees of the Public Administration, it is forbidden to offer gifts, hospitality or entertainment expenses (regardless of their value). It is forbidden to make any type of payment, offer or receive any benefit of value in the context of relations with the PA for the purpose of obtaining or maintaining an assignment or any other advantage in favor of VDR Group.

Any form of payment to political parties or organizations, to their representatives or for political campaigns, is prohibited.

VDR Group relates to the supervisory authorities with maximum transparency, clarity and correctness, so as not to induce partial, distorted, ambiguous or misleading interpretations. In consideration of the confidentiality and sensitivity of relations with these bodies, only those specifically appointed are required to liaise with public institutions and supervisory authorities.

VDR Group undertakes:

• to establish, without any type of discrimination, stable channels of communication with all institutional interlocutors at international, community and territorial levels;
• to represent the interests and positions of the Company in a transparent, rigorous and coherent manner, avoiding collusive attitudes.

The Recipient who for any reason, directly or indirectly, accesses IT or telematics systems of the Public Administration, must not alter their functioning in any way by intervening without right or in any way on data, information and programs.

In relations with the financial administration, the Company promotes the principle of transparency and clarity of the data on which the declarations provided are based, guaranteeing in any case the traceability of the choices made and the sharing of such choices with subjects with specific and proven professional skills . The Company also guarantees the full compliance of the declarations to be made with the regulations in force, using IT systems and professional consultancy in order to verify at any time the validity of the regulations having any relevance in the formation of the declarations. All aimed at paying taxes and duties in the amount due without exceptions of any kind in full compliance with the law.

VDR Group considers the population and local communities of the countries in which it is present among its main stakeholders and undertakes to promote relationships with them in the forms provided for by the laws applicable in the various systems.

The development of social initiatives, projects and events of a cultural nature and the support for various associations demonstrate the commitment of VDR Group and towards the community and the territory in which the Group operates.

The VDR Group Companies comply with the provisions of Legislative Decree, which provides for the implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council, of 23 October 2019, concerning the protection of persons who report violations of Union and containing provisions regarding the protection of persons who report violations of national regulatory provisions.

The Company has adopted – as per the indications contained in the General Part of the Model – a plurality of channels dedicated to the reporting of offenses by employees, members of corporate bodies and external collaborators.

The management of the channel of each report, to be carried out in written form, electronically or orally, is entrusted to an external party indicated in the General Part of the Model.

In managing reports, the VDR Group Companies  apply the following principles:

1. Reports cannot be used beyond what is necessary to adequately follow up on them.
2. The identity of the reporting person and any other information from which such identity can be deduced, directly or indirectly, cannot be revealed, without the express consent of the reporting person himself, to people other than those competent to receive or follow up on the reports , expressly authorized to process such data pursuant to articles 29 and 32, paragraph 4, of regulation (EU) 2016/679 and article 2-quaterdecies of the code regarding the protection of personal data referred to in the Malta legislative Law.
3. As part of the disciplinary proceedings, the identity of the reporting person cannot be revealed, where the dispute of the disciplinary charge is based on investigations that are distinct and additional to the report, even if consequent thereto.

If the dispute is based, in whole or in part, on the report and knowledge of the identity of the reporting person is indispensable for the defense of the accused, the report will be used for the purposes of disciplinary proceedings only in the presence of the express consent of the reporting person to the revelation of one’s identity.

4. Reports, internal and external, and the related documentation are kept for the time necessary to process the report and in any case no later than five years from the date of communication of the final outcome of the reporting procedure, in compliance with confidentiality obligations referred to in Article 12 of this decree and the principle referred to in Articles 5, paragraph 1, letter e), of Regulation (EU) 2016/679.
5. If a registered telephone line or another registered voice messaging system is used for the report, the report, with the prior consent of the reporting person, is documented by the personnel in charge by recording on a device suitable for storage and listening or by full transcription. In the case of a transcript, the reporting person may verify, rectify or confirm the content of the transcript by signing.
6. If an unregistered telephone line or another unregistered voice messaging system is used for the report, the report is documented in writing with a detailed report of the conversation by the assigned staff. The reporting person can verify, rectify and confirm the contents of the transcript by signing.
7. When, at the request of the reporting person, the report is made orally during a meeting with the relevant staff, it, with the prior consent of the reporting person, is documented by the relevant staff by recording on a device suitable for conservation and listening or verbally. In the case of minutes, the reporting person can verify, rectify and confirm the minutes of the meeting by signing.
8. The reporter cannot suffer any retaliation. Obviously, the possibility of the reporter to proceed at the same time or as an alternative to the reporting covered by this procedure to report to the Authorities what has been ascertained or known to him remains.