The Organizational, Management and Control Model of BORRI S.p.A. in compliance with the Italian  Legislative Decree n. 231/2001

In compliance with the Italian Legislative Decree of June 8, 2001, n. 231, Borri S.p.A. implemented its own Organizational, Management and Control Model.

This document describes the conduct that the Company's employees, and all the third parties that come into contact with it, are required to take in order to prevent the risk of committing the crimes regulated in the Italian Legislative Decree n. 231/2001 itself. In fact, if committed in the interest of or for the benefit of the Company, these crimes may result in the latter having an administrative responsibility in violation of the Italian Legislative Decree n. 231/2001, with consequent exposure of the Company to a sanctioning risk having a serious nature.

Any report, concerning illegal conduct relevant under Legislative Decree 231/2001 or violations of the aforementioned Model, has to be transmitted to the Supervisory Body of Borri S.p.A., in compliance with the terms described in the Organizational Model - General Section, Chapter 6, Paragraph a7), by email to odv@borri.it.

Ethics line: a specific system

An ethics alert system is in operation, which is accessible to all Borri stakeholders in the event of problems involving accounting and/or financial matters, corruption, competition law, serious damage to the environment or the safety of people, unethical behaviour (discrimination and harassment), data protection, or a conflict of interest. The alerts can be sent to the Compliance Officer of Group Legrand, Borri parent company, through the platform https://legrand.signalement.net/

Legrand provides the whistle-blower with protection against reprisals. This means that no one can suffer reprisals, or threats of reprisals, because they have reported an ethics or fraud issue in good faith.

Information collected by all recipients of the report and the people concerned remain strictly confidential. Anyone involved in an alert has a right to access and correct data concerning them The data subjects (issuer of the alert, persons involved in the collection or processing of the alert, person who is the subject of an alert as a victim or alleged witness of the facts) may exercise their right of access by using the whistleblowing system or by post addressed to the Group Compliance Officer. By exercising this right, these people will not receive any data relating to third-parties.

For more information about the Legrand ethics program, you can visit www.legrandgroup.com.