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 "the protection of persons who report violations of Union law and laying down provisions concerning the protection of persons who report violations of national regulatory provisions"transposes into Italian law Community legislation (EU Directive 2019/1937) to protect persons who report illegal activities or fraud within a business context, public or private, and that harm the public interests or the integrity of the entities to which they belong ("Whistleblowing legislation").

In accordance with the provisions of the law and in order to remove all those factors that may hinder or discourage the use of whistleblowing, Eudaimon has adopted a special Regulation that describes the measures applied by which it is possible to make relevant reports, ensuring the confidentiality of the reporting agent and the parties involved and their protection against any retaliatory measures.

To send reports, Eudaimon has activated a special internal reporting channel accessible through this link. In case of malfunction or unavailability of the channel, or in any case as an alternative to the use of the same, the Signaller may request a direct meeting with a member of the Supervisory Body by request to be sent to the email odv231@eudaimon.it

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.