ORGANISATIONAL MODEL 231 AND CODE OF ETHICS

For over 50 years, Tosingraf Srl has been a leader in Italy in the production and marketing of printing and post-press equipment and consumables.

The Company has adopted an Organisational, Management and Control Model drawn up in accordance with the provisions of Articles 6 and 7 of Legislative Decree No. 231 of 8 June 2001, as amended and supplemented. The Legislative Decree regulates the liability of legal persons, companies and associations for administrative offences arising from criminal offences.

The Organisational Model adopted by Tosingraf provides for specific rules and procedures to prevent the Company from being held liable as a direct consequence of an offence committed by a natural person 'for the benefit or in the interest' of the Company. In particular, the Company is liable for offences committed by:

1. Persons in senior positions, such as persons holding the position of representatives, directors or managers of the company or of one of its organisational units with financial and functional autonomy, or persons exercising management or control of the company;
2. Persons in subordinate positions, such as persons subject to the management or supervision of one of the persons in senior positions (e.g. employees or collaborators).

The Organisational Model aims to develop a corporate governance structure and a risk prevention system to prevent the commission of offences by managers, employees and external collaborators. It should also be noted that offences committed by partners or external collaborators may also result in the Company being held liable; therefore, any behaviour by partners or external collaborators that is contrary to the Organisational Model and/or the Code of Ethics may constitute a breach of contract, resulting in the termination of the contract and, where appropriate, a claim for compensation for any damages incurred by the Company.

CODE OF ETHICS

Tosingraf's Code of Ethics, an integral and essential part of the Organisational Model, identifies the company's core values, highlighting all the rights, duties and responsibilities of all those who, in any capacity, work within the Company or collaborate with it, whether they are employees, customers, suppliers, consultants, agents, business partners, public administration, civil servants, shareholders and, more generally, any other person with whom contact is established.

The 231 Organisational Model is accessible to all employees upon request, while the Code of Ethics, updated in accordance with Legislative Decree No. 24/2023, is available at the following link: Code of Ethics