Governance

ORGANISATIONAL MODEL 231

The Legislative Decree of June 8, 2001, entitled "Discipline of the administrative responsibility of legal persons, companies and associations even without legal personality" ("Decree")introduced into the Italian legal system a particular regime of administrative liability for certain offences committed, in the interest or advantage of the same: by directors, managers or employees. This responsibility is added to that of the natural person who materially realized the fact.

The Eudaimon Spa Company, sensitive to the need to ensure conditions of fairness and transparency in the conduct of business and business activities, to protect the expectations of its stakeholders and the work of its employees, in accordance with the provisions of art. 6 of the Decree, has adopted a Model of Organization and Management ("Model") aimed at preventing the commission of the different types of offences contemplated.The Model, published, for transparency purposes, in this section, aims to regulate the conduct of the parties involved, through the construction of a structured set of rules of conduct, protocols and procedures.

THE CODE OF ETHICS

An integral part of the Model is the "Code of Ethics" (also published in this section) in which are defined the values that inspire Eudaimon in the conduct of its business and in the achievement of its objectives, also for the purpose of the prevention of the crimes provided for by the Decree.For the concrete and effective implementation of the Model and for compliance with the Code of Ethics, a Supervisory Body ("odv") has been established, with operating autonomy, to which the Company has entrusted the task of supervising the functioning and observance of the Model, as well as taking care of its updating.

The ODV, external to the Company, can be contacted at the dedicated e-mail address odv231@eudaimon.it

WHISTLEBLOWING

Legislative Decree 24 of 10 March 2023, entitled ”he protection of persons who report breaches of Union law and laying down provisions concerning the protection of persons who report breaches of national laws”, transposed into Italian law the EU legislation (EU Directive 2019/1937) on the protection of persons who report illegal activities or fraud within a work context, whether public or private, and which damage the public interests or the integrity of the entities to which they belong (“Whistleblowing Legislation”).

In compliance with the provisions of the law, Eudaimon S.p.A. has made available to employees and collaborators the possibility of reporting, even anonymously, offences and/or violations of which they have become aware.

The aim is to prevent the occurrence of non-compliance or irregularities within the organisation, but also to involve all stakeholders, in an activity to combat illegality, through active and responsible participation.

All conduct, acts or omissions that harm the public interest or the integrity of the Company and of which one has become aware in the work context may be reported, as they constitute

• unlawful conduct pursuant to Legislative Decree no. 231/2001 or violations of the Organisation, Management and Control Models adopted pursuant to Legislative Decree n. 231/2001;
• offences falling within the scope of European Union acts relating to, but not limited to, the following areas: public procurement; services, products and financial markets and prevention of money laundering and financing of terrorism; product safety and compliance; environmental protection;
• acts or omissions affecting the financial interests of the European Union and/or affecting the internal market;
• violations of gender equality and the provisions of UNI/PDR 125.

The report may be made through the internal channel made available by Eudaimon S.p.A. and according to the procedures set out in the specific “Whistleblowing Policy” and will be handled in accordance with the same.

The reports are received by the Supervisory Body, guaranteeing the confidentiality of the Whistleblower. The carrying out of the investigative activity may envisage the involvement of other competent corporate Functions/Functions/Organs and/or the collaboration of external third parties, always in compliance with the confidentiality obligations as provided for by the legislation. Without prejudice to the preferential use of the internal whistleblowing channel, pursuant to Article 6 of Legislative Decree 24 of 10 March 2023, it is also possible to make a report to the relevant authority (ANAC).

The Whistleblower may not be sanctioned, dismissed, demoted, replaced, transferred or subjected to other unfavourable measures for reasons directly or indirectly linked to the reporting.

SUSTAINABILITY, QUALITY AND ENVIRONMENT

Eudaimon is aware of the importance of the social contribution of the business activity and intends to pursue the search for competitiveness in the market through the correct and functional use of its resources, in addition to compliance with purely economic requirements and in full respect of the quality of the environment and the social system, also in order to increase its ability to produce value and create welfare for the community.

In this context, Eudaimon has set itself precise objectives to achieve results of excellence. These objectives, which are the basis of the Integrated Management System implemented in Eudaimon, are formalized in the document of "Policy for quality and environment" available and viewable in this section.

IMPACT REPORT

Since 2021, Eudaimon S.p.A. has transformed into a Benefit Company (SB), embracing an even more evolved way of doing business and starting a path of further growth and commitment towards sustainability and inclusiveness objectives, to bring concrete benefits to the reality in which it falls and, in general, to those around it.  After the transformation into Society Benefit, Eudaimon has continued its evolutionary process obtaining at the beginning 2023 the certification B Corp.

The objectives identified as well as the measurement of their degree of achievement are formalized in the Impact Report, Document through which Eudaimon undertakes to report on the progress of the objectives included in the statute and to find new ways to engage first-hand for a sustainable future.

CODE OF CONDUCT FOR SUPPLIERS

Eudaimon is aware that the success of a company is measured by a combination of several factors, not only economic, and pays great attention to the fact that its activities are carried out with integrity and professionalism, pursuing high ethical standards and respecting local and international regulations.

Suppliers are a fundamental and essential part of the Eudaimon business and therefore, for any strategy or path, their participation is necessary.

The Code of Conduct is addressed to all those who work in collaboration with Eudaimon and aims to define the guidelines of conduct to be adopted every day in the management of their work activities.

UNI/PdR 125:2022 CERTIFICATION - GENDER EQUALITY.

At Eudaimon, we are committed to incorporating the principles of gender equality, articulated over the entire career path and life stages of female workers, from recruiting to retirement, with the aim of not only increasing the presence of women within the work environment but also ensuring equal career opportunities, up to the most important apical roles, equal economic treatment, work-life balance conditions appropriate to the different stages of life and proactive in the rebalancing of family loads between men and women, as well as a work environment that rejects stereotypes, discrimination, all forms of physical, verbal, and digital abuse and instead proposes a culture of diversity and inclusion.

The UNI/PdR 125:2022 reference practice is not a national standard, but is a document published by UNI (an Italian standardization body), as required by EU Regulation No. 1025/2012, reflecting the outcomes of the discussion held in the Working Table on gender certification of enterprises provided for in PNRR Mission 5, coordinated by the Department for Equal Opportunities and attended by the Department for Family Policies, the Ministry of Economy and Finance, the Ministry of Labor and Social Policies, the Ministry of Economic Development, and the National Council of Equality.

The Reference Practice defines guidelines on the management system for gender equality, which provides for the structuring and adoption of a set of performance indicators (KPIs) inherent in gender equality policies in organizations.

The Reference Practice for Gender Equality in Organizations provides for the measurement, reporting and evaluation of gender-related data in organizations with the aim of closing the gaps that currently exist as well as incorporating the new paradigm related to gender equality into the DNA of organizations and producing sustainable and lasting change over time.