Code of Ethics
and Organizational Model 231

In the context of an increasingly interconnected and regulated world, companies are called upon to ensure not only operational excellence but also legal and ethical compliance.

The “231 System,” named after Article 231 of the Italian Legislative Decree No. 231/2001, is a regulatory framework designed to prevent the commission of certain crimes within organizations. It consists of a set of rules, procedures, and controls aimed at promoting legality and ethical business conduct.

The implementation of the 231 System represents an important milestone for CAP Arreghini, demonstrating our commitment to transparency, ethics, and sound corporate governance. This step not only reflects our determination to act responsibly but also helps strengthen the trust of our stakeholders — including customers, suppliers, and investors. In an increasingly complex and regulated business environment, the 231 System provides us with a solid framework to identify, prevent, and manage legal risks.

The decision to implement this system reflects our intention to operate in line with best business practices and to safeguard the interests of our company, our employees, and the communities in which we operate.

The adoption of the 231 System offers several benefits, including:

• Reduction of legal risk: by implementing preventive and control measures, we reduce the likelihood of involvement in unlawful activities and the resulting legal consequences.
• Enhanced corporate reputation: we demonstrate our commitment to legality and ethics, improving how our company is perceived by customers, suppliers, and the broader community.
• Promotion of a compliance culture: we foster a corporate culture rooted in regulatory compliance and integrity, encouraging employees to act ethically and responsibly.
• Increased investor confidence: adopting the 231 System helps strengthen investor trust in the company by highlighting our dedication to risk management and legal compliance.

Implementing the 231 System requires a collective effort across the entire organization. It means not only adopting new policies and procedures but also promoting a corporate culture based on integrity and compliance.