Axxam is compliant to the provisions of Legislative Decree no. 231/2001, which covers “the administrative liability of legal
persons, companies and associations resulting from the fulfilment, in their own interest or advantage, of type of offences by natural persons who manage, represent the corporation or depend from it“.

After making a careful analysis and mapping all the risks, Axxam has prepared a “Model of Organisation, Management and Control” (hereinafter the “Model”) aimed to preventing the offenses estimated by the above mentioned Decree.
This Model is under the rule of an independent entity by the name of “Supervisory Board” collecting any warning of
non-compliance with the 231/2001 Decree via e-mail at the address: axxam@organismodivigilanza.com.

The Model comprises the following documants: the “Ethics Code”, which all the Axxam’s employees and anybody working for Axxam must comply with, and the “Disciplinary System”, including the measures applicable to those who fail to comply with the provisions set out in the Model.