Organizational Model of the Cafimar Group pursuant to Legislative Decree 231/01.

The Cafimar Group, in order to fully implement the indications provided by Legislative Decree 231/01 and protect all companies belonging to the Group from the administrative liability of legal persons, introduced in Italy by Legislative Decree 231/01, has adopted an Organizational Management and Control Model (hereinafter the "231 Model") aimed at preventing the commission of crimes by its employees, collaborators and directors.
In order to facilitate understanding of the use of the 231 Model adopted, as an operational tool, a brief description of what the indicated legislation provides for and what it means for a company to build a system exempting legal persons from administrative liability is provided below. .

WHAT IS THE D.lgs. 231/01

The Legislative Decree 231/2001 introduced for the first time into our legal system the principle of administrative liability of legal persons for specific types of crimes committed by company directors and employees. Today, even legal persons, such as companies, are subject to criminal liability for administrative offenses resulting from a crime.
In fact, the Decree envisages administrative liability for the company, which however takes the form of sanctions relevant to the survival of the company on the market, such as  the application of a fine up to million euros, the interdiction and suspension of the activity, the prohibition to contract with the Public Administration, the exclusion from contributions, the prohibition of advertising, the confiscation of revenues and the publication of the unfavorable sentence.
The Decree offers as the only exempt chance the possibility for companies to equip themselves with an Organizational Model capable of preventing the commission of crimes; this choice either eliminates the risk or, in any case, reduces its penalty severity.

The main steps for the implementation of an effective "Model 231" and, therefore, to protect oneself against corporate administrative criminal liability, can be summarized as follows: identification of processes at risk, potential risks and conditions for the commission of crimes in the interest or to the advantage of the entity, definition of responsibilities and activities aimed at the appropriate management of activities, construction of a map of top management, construction and dissemination of a Code of Ethics at all levels, definition and application of an adequate regime disciplinary action, establishment of a Supervisory Body (hereinafter "SB"), punctual assessment of company risks and actions aimed at containing the risks of committing crimes to an acceptable level (the acceptability of the risk level is, in fact, in verifying that the type of crime can only be committed by fraudulently circumventing the con system troll).

In order to fulfill these obligations, the company Code of Ethics was drafted which all Employees, Directors and other stakeholders are required to comply with. Said Code of Ethics, in addition to being posted on company bulletin boards, is published in the following section together with Model 231, of which the Code of Ethics is an integral part, the Regulations of the SB and the list of top management figures._d04a07d8-9cd1-3239- 9149-20813d6c673b_