Code of Ethics

Abstract

"This Code of Ethics (hereinafter the “Code”) forms an integral part of the Compliance System pursuant to Legislative Decree 231/01, as amended (hereinafter the “Compliance System”) adopted by the Board of Directors of CDP and the Group companies over which it exercises management and coordination powers (hereinafter “coordinated companies”)1 and governs the rights, duties and responsibilities that CDP and the coordinated companies expressly assume in respect of the stakeholders with whom they interact in the course of their business. The ethical standards and the values set out in the Code should guide the activities of all those who act in any way in the interests of CDP and the coordinated companies, taking account of the type of legal relationships involved and the specific provisions of laws, regulations, the articles of association and contracts applicable to each such relationship, the importance of the roles undertaken, the complexity of the functions and the responsibilities assumed or entrusted to them to pursue their objectives. Specifically, the “recipients”3 of this Code are: • the members of the corporate bodies; • employees; • associates; • consultants; • partners; • suppliers; • business counterparties. Establishing ethical guidelines and adopting standards for action are crucial to ensuring that CDP and the coordinated companies act reliably in their relations with stakeholders and, more generally, within the entire civil and economic environment in which they operate, contributing to the prevention of the offences set out in Legislative Decree 231/2001."