Ethical code

This Ethical Code has been approved by the sole director of Tuscania Real Estate Srl in
date 08/09/2023

Summary

Foreword

Tuscania Real Estate Srl is aware that the authority of a company is recognized, as well as
by the expertise of its staff and the high quality of service provided to customers, including
By the attention paid to the needs of the whole community.
The Code of Ethics (hereinafter, also, the “Code”) is a document adopted by that sets forth the principles and
Rules of conduct, compliance with which is required by the Company from all its personnel and third parties
In carrying out their activities.
The purpose of this Code is to state and disseminate the values and rules of conduct to which the Company
intends to make constant reference in the conduct of its business activities.
This Code represents a distinctive and identifying element towards the market and the
third parties, the knowledge and sharing of which, required of all those who work in the Company or who with
it collaborate, constitute the foundation of our activity and the first step in contributing to the
Pursuit of our vision.
Tuscania Real Estate Ltd.’s goal is to pursue excellence in the market in which it operates, through
Sustainable Development, safeguarding the Environment and People’s Safety, satisfy their own
customers and provide added value to all Stakeholders-“Creating Value is our job.”

purpose and target audience

This Code outlines the set of ethical and moral principles that underlie the activities of
Tuscania Real Estate srl (hereinafter, the “Company”), the lines of conduct adopted by it
within its business (in relations with employees and contractors) and
externally (with all those who, in any capacity, cooperate and collaborate with the Company, partners
commercial (i.e., “Interest Bearers”).
This Code is binding on the directors, employees and collaborators of Tuscania Real
Estate Ltd. as well as for all those who work and collaborate, permanently or on a temporary basis,
on behalf of the Company (hereinafter, the “Recipients”).
The Code will be given wide dissemination within the internal governance structure, and wide
external communication, including through its website.

GENERAL PRINCIPLES

The conduct of the Recipients, at all levels of the company, is guided by the principles of integrity, fairness and
Fair competition, Sponsorship, gifts, gratuities, non-discrimination, confidentiality and
diligence.

1.1 Integrity

The Company believes that compliance with the law, regulations and this Code is a value
primary to be constantly ensured.
The Company offers its customers quality services with the aim of efficiently responding to the
their expectations.

1.2 Fairness and Fair Competition

The Company requires Recipients to operate according to principles of fairness, fair competition and
Transparency to its staff, institutions, suppliers, distributors, customers
and all the players in the market.

1.3 Sponsorships, gifts, donations

The Society agrees to sponsor only events with corporate, cultural, sports value
or beneficial.
Personnel operating and working within the Company are prohibited from offering and receiving gifts, or
other utilities of a nature and value that can be interpreted as aimed at obtaining benefits of
any nature and in any case not in line with normal custom, this value is set within
€ 200,00.

1.4 Non-Discrimination

The Company avoids all forms of discrimination by promoting dialogue, equal opportunities, diversity
and inclusion.

1.5 Confidentiality

The Company is committed to ensuring the protection and confidentiality of personal data in compliance with
Any relevant applicable regulations.
Recipients are required not to use confidential information, learned in their business
work, for purposes unrelated to the exercise of that activity, and in any case to always act in compliance with
Of the confidentiality obligations assumed by Tuscania Real Estate Ltd. towards all Bearers of
Interests.

1.6 Diligence

The relationship between Tuscania Real Estate Ltd. its employees and collaborators is based on mutual
trust, respect and cooperation: employees and contractors are expected to work to foster the
interests of the company, while respecting the values set forth in this Code.
Recipients of this Code are expected to carry out their activities with the required diligence
from the type of assignment, with professionalism and reliability.
Where there is any doubt that there is a conflict of interest, even if only potential, the
Recipients promptly inform the Company and comply with its decisions.

2. PERSONNEL MANAGEMENT

The Company protects and values its staff by committing to respect their rights.

The Society:
– Promotes workers’ participation in the life of the company;
– provides all staff with the same opportunities, so that everyone can enjoy a
Fair treatment based on meritocratic criteria;
– Promotes a culture of health and safety in the workplace;
– Ensures an appropriate work environment for human, professional and personal growth;
– Counteracts incidents of bullying, stalking, psychological violence and any behavior
Discriminatory or injurious to personal dignity on and off company premises.

3. TRANSPARENCY AND FAIRNESS IN THE MANAGEMENT OF THE ENTERPRISE

All economic and financial operations and transactions must be recorded, authorized,
correct, truthful. verifiable, legitimate and congruous.
The Company, in preparing the financial statements and all other corporate communications required by law,
complies with the relevant codified regulations and accounting standards.

3.1 Heritage protection

All company assets must be used responsibly, avoiding any misuse
even by third parties, used and guarded with diligence.

3.2 Communication and Use of Information Systems

Tuscania requires compliance with the provisions of corporate information security regulations, at the
In order not to compromise the functionality and protection of computer systems and the data therein
contents.
It is prohibited to alter the operation of the computer system in any way or intervene
illegally by any means on data, information or programs contained in a system
computer or telematics even of third parties.
The Company promotes effective corporate communication that can connect the company
with civil society, in order to incorporate instances, needs and requirements of the community and to disseminate the
own values and mission.
The advertising promotion of Tuscania Real Estate Ltd. respects ethical values, protecting minors and
Repudiating vulgar or offensive messages.

4 EXTERNAL RELATIONS

4.1 Relations with Authorities and Public Administrations.

Relations with the Authorities and the Public Administration must be marked by the utmost
Clarity, transparency and cooperation, in full compliance with the law and according to the highest standards
moral and professional.
Recipients, unless expressly authorized, may not relate in the name and on behalf of
Tuscania Real Estate Ltd. with the Authorities and the Public Administration.

4.2 Relationship with customers, suppliers and partners

Recipients shall deal with third parties courteously, competently and professionally.
Relations with customers, suppliers and partners are marked by loyalty, fairness, transparency and in the
Respect for equal opportunity toward all stakeholders.

5 CONTROL SYSTEM

Compliance with the requirements of this Code is entrusted to the prudent, reasonable and careful
supervision of each of the Recipients, within their respective roles and functions within
of the company.
Any violation, actual or even potential, committed in to what is stated in this
Code of Ethics and in the Model can be reported by the Recipients directly to the ‘Administrator.

6 PENALTY SYSTEM

Violation of the above regulations constitutes breach of obligations under the relationship
employment and/or disciplinary offense, with all legal consequences, i.e., the application of sanctions
Disciplinary measures in accordance with current legal provisions and collective agreements applicable to the Company,
including with regard to the preservation of the employment relationship, and may result in the obligation of compensation
Of damages resulting from the violation committed.
Violation of the rules of the Code by parties outside the Company may result, in the
hypothesis of greater seriousness, the termination of the contractual relationship.

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