ORGANIZATIONAL MODEL

AND CODE OF ETHICS

ORGANIZATIONAL MODEL 231

Sitem S.p.A. has adopted the Organization, Management, and Control Model pursuant to Legislative Decree 231/2001 (MOG 231), with the aim of strengthening its governance system and preventing the commission of the predicate offenses established by the law. The Model defines a structured set of principles, rules, procedures, and controls that guide corporate operations in accordance with the values ​​of legality, transparency, fairness, and responsibility.

MOG 231 is based on:

  • risk mapping and management of sensitive activities;
  • internal protocols and controls to oversee processes;
  • a Code of Ethics and shared rules of conduct;
  • staff training and awareness-raising activities;
  • a continuous monitoring and updating system;
  • the supervision of an independent Supervisory Body (SB), responsible for verifying the effective implementation of the Model and its adequacy over time.

With this decision, Sitem confirms its commitment to solid and compliant business management, protecting customers, partners, and stakeholders and promoting a corporate culture focused on integrity.

    CORPORATE CODE OF ETHICS AND SUPPLIER CODE OF ETHICS

    Sitem S.p.A. has adopted a Corporate Code of Ethics and a Supplier Code of Ethics that define the values, principles, and rules of conduct that guide the company’s daily operations and its supply chain.

    The Corporate Code of Ethics promotes behaviors characterized by legality, integrity, transparency, fairness, and respect for people, with a focus on occupational health and safety, environmental protection, and the prevention of unethical practices.

    The Supplier Code of Ethics requires partners to adhere to the same principles, encouraging responsible and trustworthy relationships throughout the supply chain, in compliance with rights, applicable regulations, and sustainability standards.

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