CODE OF ETHICS

1. LETTER TO STAKEHOLDERS

It is with great pleasure that I share the first version of the RENATO CORTI CODE OF ETHICS, a document that defines the fundamental principles forming the identity of RENATO CORTI and guiding the behaviors and decisions of the many people who contribute daily to the management of the company.

EXCELLENCE, PASSION, THE VALUE OF HUMAN RESOURCES, and INTEGRITY have always been the core values that define our “way of doing business” and our “ethics in managing relationships with customers, suppliers, and employees.” We are aware that our creations express a distinctive uniqueness in design and production, highly appreciated by our customers and rooted in the core values that shape our identity—not only as a company, but also as a community of people. I am confident that this first version of the CODE OF ETHICS, created and shared with our human resources, will serve as an incentive to continue RENATO CORTI’s growth as a sustainable company—one that develops with particular care for employees and collaborators, clients, suppliers, public institutions, the local community, and the environment.

Thanks to the CODE OF ETHICS, the values that have always distinguished RENATO CORTI are now written in a corporate document that defines the guidelines each of us commits to follow, to further strengthen the foundation of our organization.

I hope all our stakeholders can actively contribute not only to the implementation of the CODE OF ETHICS but also to its continuous evolution. RENATO CORTI has always firmly believed that objectives can only be achieved through collaboration among the many individuals who interact daily in carrying out the company’s activities, projects, and ambitions.

Claudio Marcello Girardi
Chief Executive

2. INTRODUCTION

RENATO CORTI S.r.l. (“RENATO CORTI,” “the Company”) is a leading company in the leather goods sector, capable of developing any type of product, with a particular focus on the luxury market. The Company’s registered office is located in Milan at Via Ettore Ponti, 49; it also has another operational site in Scandicci (FI) at Via Borgo ai Fossi, 1/3-5. RENATO CORTI S.r.l. was founded in the 1970s in Milan and has since become a point of reference for major luxury brands that entrust the company with the production and distribution of their collections. The factors that have contributed to RENATO CORTI’s success can be found in the distinctive traits of its creations—passion for work, attention to quality, excellence, and product uniqueness—elements that have strengthened over time thanks to high-level skills, deep knowledge of production processes, and meticulous selection of raw materials and accessories.

RENATO CORTI has always believed that a company can be summed up by the qualities and talents of the people who are part of it. For these reasons, the Company has, for several years, undertaken an important project aimed at reinforcing the imprinting of ethical values and social responsibility on RENATO CORTI’s processes, organization, and identity. This journey has led to the drafting of the first version of the CODE OF ETHICS, a document intended to define and help all company stakeholders understand the principles and guiding values that have always characterized RENATO CORTI’s operations.

The idea behind this document is to guide the actions of all stakeholders in respecting RENATO CORTI’s ideals, by defining a risk management and control system that can prevent non-compliant situations and contribute to improving corporate performance.

• Excellence, the hallmark of every action carried out daily to create collections that reflect the skills of RENATO CORTI’s people;
• Passion and the value of human capital, people are the fundamental driver of the company’s value creation;
• Integrity, the core of the corporate culture, whose values and principles have always guided the company’s operations in compliance with legality and fairness.

3. SCOPE AND RECIPIENTS

The CODE OF ETHICS guides the behaviors and actions of RENATO CORTI and all those who act in the name and/or on behalf of the Company or in its interest, regardless of legal status. Therefore, the CODE OF ETHICS is addressed to (“Recipients”):

• internal stakeholders, such as:
  • corporate bodies and their members, who are also responsible for defining strategic objectives in line with the principles and values contained in the CODE OF ETHICS or for verifying compliance with them;
  • employees, in any capacity, who shape their actions in accordance with the principles and values expressed in the CODE OF ETHICS and who commit externally to implementing its contents.
• external stakeholders, such as:
  • collaborators and consultants, who perform activities in favor of and/or on behalf of RENATO CORTI;
  • partners, entities with which RENATO CORTI has relationships of partnership, joint ventures, production collaborations, etc.;
  • suppliers of raw materials, façon workers and/or workshops, subcontractors, and service providers used by RENATO CORTI;
  • contractors of works and services, subcontractors, employment agencies, and independent workers (excluding consultants) who carry out any activity for and/or on behalf of RENATO CORTI.

Each stakeholder is required to disseminate, understand, and comply with the principles and values contained in the CODE OF ETHICS, as well as to always report any violations committed by others.
Any violation of the CODE OF ETHICS undermines the trust that underpins the relationship with RENATO CORTI.

The CODE OF ETHICS is available in electronic format on the RENATO CORTI website. A copy of this document may be requested through the communication channels provided by RENATO CORTI.

RENATO CORTI is constantly committed to ensuring the training and/or information necessary for all stakeholders within the scope of application to have adequate knowledge of the CODE OF ETHICS.

4. CORE VALUES AND PRINCIPLES

The success of RENATO CORTI has been marked by certain core values and principles, which are an essential part of a document aimed at guiding the actions of corporate stakeholders—the CODE OF ETHICS. These values must serve as a reference point for RENATO CORTI’s stakeholders.

EXCELLENCE

The continuous pursuit of excellence summarizes the entire history of RENATO CORTI. The high level of expertise developed in the design processes, selection of raw materials, and creation of all collections is the result of a path based on goals of growth, innovation, and continuous improvement, where passion for beauty and attention to detail are the guiding principles that enable the achievement of ever more ambitious and motivating milestones. These ideals are shared from the smallest artisanal workshop to the largest production plants, making RENATO CORTI a benchmark in the luxury leather goods sector.

PASSION

Passion is the element that unites RENATO CORTI’s employees, collaborators, and suppliers. Passion is the feeling, the enthusiasm, that allows the Company to always ensure excellence, within a path of growth and continuous improvement. RENATO CORTI has always been committed to passing on the passion for its craft to employees and everyone involved in achieving the company’s goals.

VALUE OF HUMAN CAPITAL

RENATO CORTI believes that the company and its successes are the result of the talents and skills of its people. The Company promotes training, professional development, and the enhancement of all human resources. Aware of the centrality of every person’s and collaborator’s work, RENATO CORTI recognizes respect, dignity, and merit as fundamental requirements of an ethical and responsible enterprise.

The Company is committed to ensuring that diversity and freedom of expression are key factors in the corporate culture. Safeguarding equal opportunities and preventing discrimination are core values that must be respected by all stakeholders.
RENATO CORTI does not tolerate and actively combats all forms of discrimination, harassment, and violence, with particular attention to differences in ethnicity, skin color, gender, sexual orientation, religion, nationality, age, political opinion, marital and socio-economic status, and trade union affiliation.
RENATO CORTI believes that health and safety in the workplace are a fundamental right of every employee or collaborator and require specific protections.

INTEGRITY

RENATO CORTI promotes compliance with laws and its own principles and values in all activities, ensuring that no unlawful behavior or actions contrary to the company’s identity are ever justified. The Company requires all parties acting in its name and/or on its behalf to behave fairly, honestly, and transparently, to honor commitments, to not accept benefits for themselves or others, and to act with diligence and good faith.
RENATO CORTI is constantly committed to ensuring that these goals and principles are translated into procedures, rules, and management and control systems capable of guiding the behaviors of all stakeholders and preventing situations contrary to the law and the CODE OF ETHICS.
RENATO CORTI believes that value creation can only be sustainable when the conduct of all those involved respects not only laws but also the values and principles contained in the CODE OF ETHICS.

5. RULES DEFINING OUR IDENTITY

5.1. RELATIONS WITH EMPLOYEES

RENATO CORTI recognizes the value of human resources and their importance in achieving strategic objectives. For this reason, the Company believes that dignity, enhancement, respect, and freedom of expression are fundamental requirements to be preserved within the workplace.

Management and managers are responsible for ensuring compliance with the principles and values contained in the CODE OF ETHICS. They must promote the development of a working environment focused on recognizing the value of resources and ensure that all relationships are based on:

• objectivity and impartiality in the assignment of tasks and duties, in identifying rewarding requirements, and in career mechanisms;
• enhancement of individual characteristics within all training processes and actions for human capital development;
• promotion of relationships based on mutual respect and the dignity of every individual;
• protection of human rights, safeguarding against child labor and promoting diversity and inclusion;
• prevention of intimidation, threats, harassment, or abuse in any form that contributes to creating a hostile work environment;
• recognition of freedom of association and collective bargaining;
• protection against any form of discrimination, with particular attention to differences in: ethnic origin, skin color, gender, sexual orientation, religion, nationality, age, political opinion, marital and socio-economic status, and trade union affiliation;
• protection of health and safety in the workplace, ensuring that applied standards comply with the law and adopting all necessary measures to prevent risk and danger to health, with a specific commitment to:
• assessing risks that cannot be eliminated and planning an adequate prevention program;
• providing suitable protective equipment;
• issuing appropriate instructions;
• monitoring the application of safety measures;
• informing, training, and raising awareness among all internal workers so they perform their duties safely;
• promoting the participation and consultation of workers;
• protecting workers from possible retaliation following the reporting of incidents, hazards, risks, and opportunities;
• spreading information about company risks to all workers and external operators;
• responding promptly, effectively, and diligently to emerging needs during work activities;
• fostering collaboration among all resources.

RENATO CORTI requires management and managers to report any violation of the CODE OF ETHICS, with particular attention to the company’s supply chain.

RENATO CORTI requires all professional figures, employees or collaborators, to:

• acknowledge and comply with the values, principles, and rules of conduct contained in the CODE OF ETHICS;
• perform their duties diligently, effectively, fairly, and honestly;
• refrain from: a) directly or indirectly accepting, including through intermediaries, money, gifts, services, favors, or other benefits from individuals or entities that are or intend to enter into business relations with RENATO CORTI; b) directly or indirectly offering, including through intermediaries, money, gifts, services, favors, or other benefits not attributable to normal business relations and which could be interpreted as a means to obtain preferential treatment in the execution of any activity related to RENATO CORTI;
• behave ethically and honestly with other RENATO CORTI personnel and all external parties they come into contact with;
• promote cooperation in work relationships;
• prevent any form of discrimination in work relationships and with all external parties, with particular attention to differences in: ethnic origin, skin color, gender, sexual orientation, religion, nationality, age, political opinion, marital and socio-economic status, and trade union affiliation;
• preserve and safeguard company assets, using any company property with care and in compliance with applicable laws;
• protect the privacy and respect the personal information of other workers and all individuals they interact with during the performance of their duties;
• protect industrial and intellectual property, refraining from:
  • conducts that may violate or infringe industrial or intellectual property rights;
  • purchasing and/or using goods with counterfeit trademarks;
  • any action that may compromise or disclose, in any way, the industrial and intellectual property of the Company or others.
• comply with all rules and codes of conduct imposed for the protection and safeguarding of health and safety in the workplace;
• promptly report any violation of the CODE OF ETHICS, with particular regard to the company’s supply chain.

5.2. RELATIONS WITH SUPPLIERS

Suppliers represent a strategic resource. For these reasons, the company encourages all employees and collaborators to establish supply relationships that are transparent and based on mutual respect and dialogue. RENATO CORTI is committed to raising awareness among all suppliers, of any product and/or service, on the principles and rules contained in the CODE OF ETHICS, with particular reference to the topics of human rights and workplace health and safety.

The company ensures that all relationships with suppliers are conducted in compliance with the law and the principles contained in the CODE OF ETHICS. Supplier identification and selection processes are based on adequate and objective criteria, ensuring that commercial terms are defined based on market conditions and are related to the quantity and quality of goods, services, or work performed. RENATO CORTI systematically verifies supplies and the performance of all suppliers, determining their qualification from time to time. Any form of favoritism and/or discrimination is not tolerated by RENATO CORTI.
In addition to respecting transparency and fairness, RENATO CORTI ensures that all supply relationships are conducted under excellent conditions, respecting the highest quality and workplace safety standards for all individuals involved. RENATO CORTI guarantees the integrity and legality of all supply relationships, avoiding the establishment or continuation of existing relationships in cases of suspected affiliation with or involvement in criminal organizations.

Respect for the principles contained in the CODE OF ETHICS is the foundation of every supply relationship.
Any violation undermines the conditions of professionalism, integrity, and legality of business relationships, thereby nullifying the potential stipulation or continuation of supply agreements.

Specifically, RENATO CORTI is committed to:

• respecting the principles and laws of fair competition;
• ensuring objectivity and impartiality in the supplier identification and selection process;
• providing fair compensation in line with the relevant market;
• not exploiting vulnerable conditions or the possession of privileged information;
• making payments only to the direct recipients and according to agreed timelines;
• not accepting personal advantages or any form of privilege;
• banning practices and forms of corruption and discrimination;
• informing, raising awareness, and training its suppliers on the principles of the CODE OF ETHICS, with particular attention to human rights, working conditions, and workplace health and safety;
• verifying compliance with human rights and all workplace health and safety requirements provided by law through regular systematic audits conducted on objective parameters and carried out at the sites of the most strategic suppliers.

RENATO CORTI requires all suppliers to:

• acknowledge and comply with the values, principles, and rules of conduct contained in the CODE OF ETHICS;
• provide accurate and truthful information, excluding situations involving possession of privileged information about the company that could generate any type of advantage;
• ensure the satisfaction of expectations, quality, professionalism requirements, and delivery times;
• guarantee the protection of privacy and sensitive and personal information;
• safeguard industrial and intellectual property;
• ban active and passive corruption, including all forms of behavior aimed at directly or indirectly generating any type of advantage for themselves or others;
• promptly report any violation of the CODE OF ETHICS.

5.3. RELATIONS WITH PUBLIC ADMINISTRATION

Relations with Public Administration include all interactions with public or private entities, Italian or foreign, that perform authorizing, inspection, legislative, or public goods and services production functions, or that respond directly to requests made by the company.

RENATO CORTI ensures that all relationships held directly or indirectly with Public Administration are based on the principles of clarity, transparency, fairness, and impartiality. The company encourages all corporate functions involved and authorized to cooperate and comply with all applicable laws and regulations in dealings with Public Administration.

In particular, RENATO CORTI requires:

• guaranteeing the autonomy of public officials with respect to all those who, in the name and/or on behalf of RENATO CORTI, are called to provide information and company data;
• cooperating with inspection and judicial bodies during procedures or actions, avoiding omission, reticence, or obstruction;
• refraining from directly or indirectly offering, including through intermediaries, money or other benefits to public officials, their family members, or any related subjects, to seek or establish favorable, influential, or interfering relationships. Any form of courtesy towards such subjects is only permitted if of modest value and, with respect to a specific occasion, considered usual and not such as to affect the judgment or opinion of the recipients;
• refraining from hiring, directly or indirectly, public officials or employees, including their family members or related individuals, who have actively participated in inspection or authorization activities regarding RENATO CORTI;
• refraining from accepting requests from public officials for money, gifts, or services, to perform or refrain from performing or to facilitate any activity falling within their professional duties;
• not requesting or attempting to obtain personal and/or confidential information from public officials, including about other individuals, that may influence inspection or judgment processes in violation of the principle of equal treatment or of the rules and standards provided;
• not providing contributions or funds of any kind or nature in support of public officials, their family members, or any related individuals, except as allowed and provided by laws and regulations;
• respecting the purposes of contributions and/or subsidies received in any capacity from Public Administration.

5.4. RELATIONSHIPS WITH COMPETITORS AND CONFLICTS OF INTEREST

RENATO CORTI promotes the principle of free competition in all markets and sectors, committing to comply with laws that protect competition and the free market in every country where the company operates. In the same spirit, the company opposes cartels, monopolies, and market regulation agreements, and prohibits any abuse of dominant position.

In accordance with the principles of free competition, honesty, and entrepreneurship, RENATO CORTI requires all employees and collaborators to avoid situations of conflict of interest and to promptly report any potential conflicts involving the company and its stakeholders. Situations considered as conflicts of interest include, but are not limited to: a) holding, directly or indirectly, control or management positions in competing, client, or supplier companies; b) engaging in work and/or professional activities, even indirectly, with competing, client, or supplier companies; c) accepting money, contributions, or favors from competing, client, or supplier companies; d) using one’s position to benefit, even through the exchange of information or sensitive data, competing, client, or supplier companies; e) concluding or finalizing negotiations or business on behalf of RENATO CORTI with counterparts who are relatives, partners, or managers of competing, client, or supplier companies.

5.5. RELATIONSHIPS WITH THE COMMUNITY

RENATO CORTI actively supports the local community through projects, donations, sponsorships, and charitable contributions. As part of these initiatives, the company is committed to identifying and engaging with reliable parties who adhere to the principles and rules outlined in the CODE OF ETHICS.

5.6. RELATIONSHIP WITH THE ENVIRONMENT

RENATO CORTI is continuously committed to ensuring environmental sustainability in its daily activities. The environment is a valuable resource that must be protected to ensure a more sustainable future for the next generations. The company also expects its stakeholders to share and commit to the same values by:

• raising awareness, informing, and educating on environmental sustainability and actions to combat climate change;
• complying with environmental laws applicable in the countries where the company operates;
• promoting awareness on:
  • mitigating the environmental impact of company activities;
  • reducing the consumption of natural resources (especially water and energy);
  • using and/or producing energy from renewable sources;
  • reducing waste and greenhouse gas emissions;
  • monitoring and reducing environmental and climate risks.

5.7. REPRESENTATION OF ECONOMIC AND FINANCIAL RESULTS

RENATO CORTI ensures the transparency, accuracy, and integrity of the information shared with stakeholders. The company commits to complying with all applicable laws and accounting standards to ensure that reported financial results are a clear, accurate, and truthful representation of its business performance and economic condition. To this end, the company requires every employee, collaborator, or professional working on its behalf to:

• record each transaction accurately in the accounting system;
• establish appropriate accounting procedures to promptly and precisely reflect business activities;
• actively cooperate with the auditing body and provide all necessary information to allow for an accurate and complete assessment;
• cooperate fully with public officials who request data or information during the course of their duties;
• apply their best expertise when performing assigned tasks;
• ensure an adequate level of transparency and accuracy in information disclosed externally.

5.8. ANTI-CORRUPTION

RENATO CORTI has always upheld legality, honesty, and integrity in every decision and action undertaken. The company rejects all forms of corruption, active or passive, at any organizational level, both in Italy and abroad. RENATO CORTI promotes legal compliance and a corporate culture aimed at preventing any actions or behavior contrary to the principle of zero tolerance for corruption.

In line with the other principles of the CODE OF ETHICS, RENATO CORTI is committed—and requires all Recipients to commit—to:

• not engage in any corrupt practices or offer money or other benefits to serve a private interest or influence a public official’s actions;
• discourage all forms of corruption or inducement to corruption;
• ensure the independence of public officials when providing corporate information or data on behalf of RENATO CORTI;
• cooperate with inspection and judicial bodies during investigations, avoiding omission, concealment, or obstruction;
• refrain from offering, directly or indirectly, money or benefits to public officials, their family members, or anyone connected to them to gain favor, influence, or interference. Acts of courtesy may be acceptable only if modest in value, customary, and do not compromise judgment or opinion;
• refrain from hiring public officials, their relatives, or related parties who have been involved in inspections or authorizations concerning RENATO CORTI;
• refuse any request from a public official for money, gifts, or services to perform or refrain from performing an activity related to their official duties;
• not request or obtain personal or confidential information from public officials about others in violation of equality and legal standards;
• not provide contributions or funds of any kind to support public officials, their family members, or anyone related to them, except as permitted by law and regulation;
• respect the purpose of any contributions or grants received from Public Administration;
• ensure transparency and traceability in dealings with Public Administration, Institutions, or other public or private entities with legislative, supervisory, or authorization roles;
• comply with all anti-money laundering laws and regulations in force;
• report any suspicious transaction related to money laundering or involving parties seeking to disguise illicit proceeds as lawful income.

5.9. PROTECTION OF INDUSTRIAL AND INTELLECTUAL PROPERTY

RENATO CORTI strives for excellence in all processes, including those entrusted to external parties. To ensure this, the company actively protects industrial and intellectual property rights—whether belonging to RENATO CORTI or to third parties—under all relevant national, EU, and international laws and agreements. Intellectual and industrial property, patents, trademarks, logos, copyrighted materials, inventions, trade secrets, and other confidential internal information—including business plans, designs, models, marketing and sales data, procurement, organizational structure, and production resources—are critical assets that underpin RENATO CORTI’s competitive advantage. RENATO CORTI strictly prohibits the use of such information, especially technical and process-related, by unauthorized third parties. In supplier relationships, RENATO CORTI requires the establishment of safeguards to prevent any infringement of its or third-party intellectual and industrial property rights, especially concerning entrusted information and data.

RENATO CORTI expects all stakeholders to:

• respect intellectual and industrial property rights, rejecting any alteration or counterfeiting of trademarks, industrial products, trade secrets, designs, or models;
• refrain from purchasing or marketing counterfeit products or those infringing on RENATO CORTI’s or third-party property rights;
• protect and safeguard RENATO CORTI’s or third-party intellectual and industrial property with confidentiality and discretion, and not disclose related data or information without RENATO CORTI’s express authorization. This includes industrialized patterns, assembly and cutting instructions, testing procedures, and specific production tools;
• not use any data or technical/administrative information, even if not expressly marked as confidential or even if shared directly by RENATO CORTI, for personal or third-party benefit outside RENATO CORTI’s specific interests.

Each stakeholder is in any case required to safeguard intellectual and industrial property and to protect all RENATO CORTI and third-party data, information, and industrial know-how (when acquired by RENATO CORTI), ensuring that access is limited only to expressly authorized persons.

5.10. PROTECTION OF PRIVACY AND CONFIDENTIALITY

The desire to compete and pursue excellence has led over time to the development of advanced know-how in all company processes and activities. RENATO CORTI believes that confidentiality is a fundamental rule in all stakeholder relationships and must be safeguarded with regard to any sensitive, confidential, or private company information.

RENATO CORTI is also committed to processing, in compliance with all applicable laws and best practices, all information related to its employees, collaborators, and third parties acquired in the course of business activities. Personal data is handled with appropriate safeguards and procedures to prevent misuse or unlawful use.

To protect privacy and confidentiality, RENATO CORTI requires stakeholders to:

• comply with all measures and procedures to ensure the confidentiality of information and data (unless authorized);
• commit to protecting the information of all individuals who interact with RENATO CORTI;
• refrain from sharing confidential information or data without explicit authorization from RENATO CORTI or the directly or indirectly concerned parties;
• respect applicable data protection laws;
• implement appropriate security and protection measures for both personal and company data.

6. IMPLEMENTATION, CONTROL, AND MONITORING SYSTEM

RENATO CORTI requires all stakeholders, especially management, to commit to respecting and ensuring compliance with the values, principles, and rules of conduct outlined in the CODE OF ETHICS.

6.1. REPORTING

All Recipients of the CODE OF ETHICS who become aware of situations—even potentially—contrary to the CODE OF ETHICS or the rules of conduct adopted by RENATO CORTI must promptly inform the Ethics Committee, which will immediately assess the validity of the reported violations, including by contacting the whistleblower and/or the alleged offender. Other reporting channels are available: supervisors, the Workers’ Safety Representative, the Occupational Physician, and all figures designated under Legislative Decree 81/2008 concerning health and safety at work. All reports, regardless of the channel used, are treated with maximum confidentiality, ensuring anonymity and thorough investigation of all relevant details. RENATO CORTI guarantees full protection from any form of retaliation or discrimination for those who report in good faith—even potential violations of the CODE OF ETHICS.

Those making a report must not conduct preliminary investigations unless formally requested by the appropriate authorities. All Recipients of the CODE OF ETHICS must fully cooperate during investigations and provide any information they possess regarding alleged violations, even if considered minor.

6.2. VIOLATIONS

The Ethics Committee evaluates reports and proposes any necessary measures to the Chief Executive, hears the person who made the report and/or the person responsible for the violation, and provides justification for its assessments.

The principles of the CODE OF ETHICS are among the conditions governing employment relationships. Therefore, employees, managers, agents, and directors who violate the provisions of the CODE OF ETHICS are subject to specific disciplinary sanctions, in full compliance with the law, the National Collective Labor Agreement (CCNL), and any applicable specific agreements. Any violation of the rules of conduct defined in the CODE OF ETHICS constitutes a breach of employment obligations and/or a disciplinary offense. Compliance with these principles is also part of the contractual obligations undertaken by consultants and other parties having relationships with RENATO CORTI. Any violation, considered a breach of contractual obligations, may lead to termination of the contract or assignment and to compensation for any resulting damages. RENATO CORTI is committed to including contractual clauses concerning violations of the CODE OF ETHICS in agreements with suppliers, collaborators, and external consultants.

All appropriate measures will be taken against individuals who engage in unlawful conduct, regardless of any action taken by judicial authorities.

6.3. IMPLEMENTATION AND DISSEMINATION

RENATO CORTI has adopted this CODE OF ETHICS with the aim of strengthening the ethical imprint and social responsibility within the company’s processes, organization, and identity.

This first version of the CODE OF ETHICS, intended to define and promote understanding—among all company stakeholders—of the guiding principles and values that have always inspired RENATO CORTI’s operations, was approved by the Chief Executive. Any future updates or revisions will be assessed by the Ethics Committee at least every three years.

The CODE OF ETHICS is available on the website www.renatocorti.it and is shared with all Recipients.

Specific training and information events are also organized for RENATO CORTI employees and collaborators to ensure full understanding and awareness of the values, principles, and rules of conduct outlined in the CODE OF ETHICS.