Italian Legislative Decree No. 231/2001 introduced a specific form of administrative liability of entities for certain criminal offenses committed, in their interest or for their benefit, by persons holding managerial or representative positions or by persons subject to their direction or supervision.

 In line with its commitment to ethical business conduct, transparency and compliance with applicable laws, VisMederi S.r.l. has adopted an Organization, Management and Control Model pursuant to Legislative Decree No. 231/2001 (the “Model”), together with a Code of Conduct.

 The Model establishes principles, rules and control measures aimed at preventing the commission of offenses covered by Legislative Decree No. 231/2001 and promoting responsible and compliant conduct throughout the organization. The implementation and monitoring of the Model are overseen by an independent Supervisory Body (Organismo di Vigilanza – “OdV”)

The Model has been adopted in accordance with the applicable legal framework and with reference to the relevant Confindustria Guidelines.