Disclosure Model 231 | Code RPA – Rev. 00 dated 20/11/2023

In compliance with Legislative Decree No. 231/01, Mastria Vending S.r.l. has adopted the "Organizational Model 231" aimed at preventing the commission of crimes that may result in the administrative liability of the Company if carried out in its interest or for its benefit.

The generally accepted principles of transparency, fairness, and loyalty that inspire the company are at the core of the adoption of Organizational Model 231, which ensures the effective execution of sensitive activities by preventing, through the application of the provisions of Legislative Decree No. 231/2001, the commission of crimes that may result in the administrative liability of the company if carried out in its interest or for its benefit.

The purpose of the Organization, Management, and Control Model (hereinafter also "Model") is to construct a structured and organic system of procedures and control activities aimed at preventing the crimes referred to in Legislative Decree No. 231/2001, by identifying activities exposed to the risk of crime and their consequent proceduralization.

Through the adoption of the Model, Mastria Vending S.r.l. aims to pursue the following main objectives:

• establish ethical values and principles of professional conduct;
• make the Recipients of the Model aware that, in case of violation of the provisions contained therein, they may incur in the commission of offenses punishable by criminal sanctions against themselves and administrative sanctions against the Company;
• reiterate that such forms of illicit behavior are strongly condemned by Mastria Vending S.r.l., as they (even if the Company were apparently in a position to benefit from them) are in any case contrary, in addition to legal provisions, also to the ethical principles to which it intends to adhere in the exercise of its business activities;
• enable the Company, thanks to monitoring of high-risk activity areas, to intervene promptly to prevent or combat the commission of such crimes. Any violation of Model 231 can be reported to the Supervisory Body established within the Company at the certified email address roccosgro@pec.it

Reports for the prevention of corruption (pursuant to and for the purposes of Legislative Decree No. 24/2023)

The whistleblowing institution is a legal instrument aimed at protecting workers who report illicit activities or fraudulent activities carried out within their organization and committed for its benefit. Legislative Decree no. 24 of 10 March 2023 has recently strengthened the measures already provided for in the Italian legal system since 2017, requiring the employer or entity to make available to potential whistleblowers a series of measures aimed at guaranteeing, also through the use of encryption tools, the confidentiality of the whistleblower's identity, the person involved and the person mentioned in the report, as well as the content of the report itself and the related documentation. The decree identifies both the individuals who can report, and the nature of the violation subject to the report (by way of example but not exhaustive, it includes administrative, accounting, civil or criminal offenses; conduct constituting the offenses referred to in Legislative Decree no. 231/2001 and violations of organizational, management and control models; violations of community regulations; etc.), as well as the procedural steps that the person in charge must follow in managing the said report. Reports can be submitted both in writing – by filling out the attached form and sending it to the Reporting Manager – and orally through an interview with the Manager. Società Mastria Vending S.r.l. has appointed Dr. Maria Stefania Consarino as the Manager of Reporting. Reports can be sent to the Certified Email address: mariastefania.consarino@legalmail.it using the attached form.