Code of Ethics and Anti Bribery guidelines

These Anti-Bribery Guidelines are a policy document issued by the company’s top management to identify and set up anti-corruption strategies by specifically analysing the risks of bribery that can be actually identified in the company and by drawing up relevant protocols, regarded as organisational tools to prevent the risk of bribery. The aim of the Anti-Bribery Guidelines therefore is to identify specific ethical and behavioural rules for combating bribery, which establish as illegal all of those activities carried out by employees, consultants and associate workers for or on behalf of the company, which allow the latter, either directly or indirectly, to achieve an illegal interest and/or advantage. The effective and tangible implementation of the Anti-Bribery Guidelines is ensured not only through adequate personnel reporting/training but also by using a system of specific surveys and/or by gathering and analysing information, reports and violations. In order to ensure effective application of
the document, disciplinary measures are applied in the event of a breach, regardless of whether these breaches have actually led to corrupt behaviour or have exposed the Company to sanctions. General Noli does not accept any form of bribery and is committed to abiding by the anti-
bribery laws in force in all countries in which it operates. The purpose of the Guidelines is to guarantee principles of transparency and to ensure clarity with regard to permitted conduct and compliance with relevant anti-bribery legislation wherever General Noli conducts its business.