Code of Ethics

This Code of Ethics (hereinafter also referred as the “Code”) expresses the ethical principles and values embraced by [1] PANINI S.p.A. (hereinafter also referred as “PANINI” or the “Company”) in conducting business and corporate activities. The Code also represents the measures the Company intends to adopt in terms of ethics and conduct to ensure its structure is in line with the requirements set out in Italian Legislative Decree no. 231/2001 (hereinafter also the “Decree”) and prepare the Company's internal and external conduct guidelines to pursue corporate goals[2]. Therefore, the principles contained in this Code involve and encompass the organisational and management models specified in art.6 and 7 of Italian Legislative Decree 231/2001.

The Code of Ethics consists of the following:

general principles, i.e. values regarded as fundamental values shared and acknowledged by the Company to assert its mission. The various stakeholders involved are required to draw inspiration from them to help the Company work better, as well as promote its reliability and reputation
criteria of conduct towards each class of stakeholder and providing the guidelines and standards that PANINI's Collaborators are required to comply with in order to respect the general principles and prevent the risk of unethical behaviour
implementation methods, which describe the control system to ensure compliance with the Code and its ongoing improvement

PANINI confirms – also through this document – that it intends to lay the foundations for a new set of corporate ethics to face the challenges imposed by markets. Collaborators therefore undertake to follow the principles and provisions contained in this Code, as well as in other ethical and behavioural policies adopted by the Company.

Collaborators therefore undertake to follow the principles and provisions contained in this Code, as well as in other ethical and behavioural policies adopted by the Company.

Panini S.p.A. - Code of Ethics

Organization, Management and Control - General part

[1] The term Collaborator refers to the managers, employees and figures who, thanks to specific mandates or powers of attorney, represent the company before third parties.

[2] A company's reputation is one of its most valuable assets. Everyone has the duty to protect and improve that reputation and ensure the company follows the laws, regulations and ethical models applying to a typical activity. The recipients of the Code need to be familiar with relevant laws and ethical standards, as well as with the company's applicable policy and directives.