Organisation, Management and Control Model (Legislative Decree no. 231/2001)

FSTechnology SpA has adopted an Organisation, Management and Control Model pursuant to Legislative Decree no. 231/2001 which establishes protocols, rules, tools and conduct that constitute a suitable system to identify and prevent the risks of committing the relevant crimes pursuant to Legislative Decree no. 231/2001 by its employees and all those who strive to achieve the Company's objectives, subject to management or supervision by the same.

The FSTechnology SpA Model 231, adopted in April 2020 following its business launch, is subject to progressive updates with respect to changes in the company's organisation and activities and to changes in case law, such as to mark new interpretative guidelines of the regulations provided for by the Model.

Anti Bribery&Corruption management system

FSTechnology SpA has voluntarily established and adopted its own Anti Bribery & Corruption management system (ABC system) to prevent corruption in the "broad" sense.

This framework aims to prevent acts and behaviour, even if they do not constitute a specific type of crime, which constitute cases of deviation from internal rules and procedures and may prejudice the good performance and general interest of the Company (cases of mismanagement and malfunctioning).

The ABC system is part of the FSTechnology SpA Internal Control and Risk Management System (SCIGR) and constitutes, together with the Organisation, Management and Control Model, a central element of the Company's Single Anti-Corruption Framework, as a unique self-regulatory tool to prevent corruption.

The FS Group’s Anti-corruption Policy is a clear and unequivocal expression of the principle of zero tolerance for corruption on which the FS Group bases its business, in the belief that acting in accordance with legality and integrity, besides being a legal obligation and a moral duty, reflects on the achievement of the objectives and reputation of the individual companies and of the Group whilst contributing to creating value, also for stakeholders, with a view to the pursuit of sustainable success.

Management of Whistleblowing Reports

FS Technology SpA has adopted a process for receiving, analysing and processing reports (also anonymously) concerning FS Technology SpA submitted by third parties or FS Italian Group personnel in order to contribute to the prevention of unlawful acts, irregularities or conduct in breach of the Organisational, Management and Control Model pursuant to Legislative Decree no. 231/2001, of the Anti-bribery & Corruption Management System, of the FS Group Code of Ethics, of laws or regulations.

The process complies with the regulatory changes introduced by Legislative Decree no. 24 dated 10 March 2023 implementing Directive (EU) 2019/1937 of the European Parliament and Council of 23 October 2019 on the protection of whistleblowers who report breaches of European Union law and on provisions for protecting whistleblowers who report breaches of national laws (the “Whistleblowing Decree”). FSTechnology SpA has activated a dedicated IT platform as the preferred tool for submitting and managing reports, being best suited to protecting the confidentiality of the whistleblower’s identity by using IT means that also ensure adequate information security measures.