Anti-Corruption Policy

De Vellis Servizi Globali, an industrial group specialized in moving, transportation, storage, and archiving services, recognizes the primary importance of conducting its business in compliance with the law and with integrity, transparency, and fairness in all the countries where it operates.

To this end, De Vellis Servizi Globali promotes an Anti-Corruption Policy in line with the Code of Ethics and actively supports all initiatives aimed at strengthening the standards and principles that must govern the conduct of all personnel, in accordance with applicable regulations, and in a manner that does not prejudice the Company, even in terms of image or reputation.

De Vellis Servizi Globali adopts an anti-corruption program inspired by the goal of “zero tolerance.” The Company’s Anti-Corruption System is based on the following principles:

− all types of corruption in any form or manner, in any jurisdiction, involving not only Public Officials but also private individuals, are prohibited;

− any practice sanctioned by Multilateral Banks is prohibited;

− all transactions must be accurately recorded in accordance with accounting principles, in a complete and transparent manner to trace all receipts, payments, and in general all transactions.

The Company defines the appropriate measures to pursue the above-mentioned principles, applies all necessary procedures to verify compliance with this Policy, the Code of Ethics, and applicable Anti-Corruption Laws, and subjects the content of its Anti-Corruption System to constant review and monitoring, in accordance with the UNI ISO 37001:2016 principles. The implementation of this Policy is the direct responsibility of the administrator, managers, and employees of De Vellis Servizi Globali S.r.l., as well as all those who, directly or indirectly, permanently or temporarily, establish relations and relationships with De Vellis Servizi Globali, each within the scope of their functions and responsibilities (the “Recipients”). Each director and manager is responsible for ensuring compliance with the Anti-Corruption System by their collaborators.

Recipients are encouraged to adopt behavior in every circumstance that complies with this Policy and Anti-Corruption Laws and will not be subject to disciplinary sanctions or retaliations of any kind if they refuse to violate them. Recipients are encouraged to report any potential violation of the Anti-Corruption System they become aware of, even indirectly, during their activities, and whistleblowers are guaranteed protection from any form of retaliation, discrimination, or penalty, without prejudice to legal obligations.

To this end, De Vellis Servizi Globali S.r.l. has appointed the Chairman of the Supervisory Board, designated for the adoption of the organizational model pursuant to Legislative Decree 231/01, as the Anti-Corruption Officer.

Any employee or collaborator who does not act in accordance with this Policy will be subject to disciplinary action, proportional to the seriousness of the violation committed. Any partner or supplier who does not act in accordance with this Policy will be subject to contractual disciplinary actions.

De Vellis Servizi Globali communicates this Policy to the Recipients and periodically updates its contents.

> WHISTLEBLOWING - 'Reporting Unlawful Conduct'

Rome, February 10, 2023

Sole Director
Ennio De Vellis