CORPORATE GUIDELINES

Charter of Ethical Principles

Integrity, transparency and responsibility in every action.

The Ethical Principles set out in the following Charter are part of our cultural heritage – understood as corporate culture – which every Person draws upon in carrying out their work activities and which must shape business dealings with third parties.

In addition to disseminating the contents of the Charter internally, we are also committed to promoting them externally, so as to be a champion of ethical values and principles throughout the value chain. We are inspired by a culture of integrity, by which we mean not the mere compliance with rules but a proactive commitment to ethical conduct that makes the alignment of our actions with legal requirements innate, on the basis of shared values.

ALBA

Alba's Principles are cornerstones that guide every decision.

1

Commitment

Compliance with current laws and the principles of integrity, transparency and the fight against corruption is the first pillar on which a responsible and sustainable business is founded. The public dissemination of the Ethical Principles strengthens their value and their ability to make an impact beyond mere compliance. Adherence to this Charter of Ethical Principles is even more valuable and may inspire emulation by other business partners, the more it is internalised and applied within and outside the company. For this reason, organising specific moments dedicated to information, training and collective awareness-raising, also aimed at spreading knowledge of our Charter within the company, is essential for us and must involve both our People, from the moment they are hired, and all third parties intending to enter into business relationships with our company.

2

Integrity

Ethical and moral integrity, honesty and uprightness in everyday business practices are principles we draw upon and that guide us in our daily work activities, also in order to consolidate our corporate reputation among stakeholders as a serious, reliable and professional partner.

3

Transparency

Transparency, meaning the organisation's openness to dialogue and to sharing relevant information, is a fundamental principle for us, also in order to promote the development of relationships based on mutual trust and the adoption and dissemination of ethically correct practices and behaviour.

4

Zero tolerance for corruption

We recognise corruption, in all its forms, as an evil capable of causing serious and negative social, reputational, economic and civic effects, impoverishing the country and damaging the companies that operate within it. In line with the above, no payment or provision of other benefits is offered or accepted that is not consistent with the principles of fairness, honesty and compliance with current regulations. Facilitation payments are also prohibited, that is, payments or provision of other benefits to Public Officials or persons in charge of a Public Service, made for the purpose of speeding up or facilitating routine activities that are due in any case (i.e. customs procedures, issuing of visas, etc.). In this regard, no form of gift is permitted that could even merely be interpreted as exceeding normal commercial or courtesy practices, or in any case aimed at obtaining favourable treatment in the conduct of any company activity.

5

Managing conflicts of interest

We resolutely and carefully avoid the emergence of conflicts of interest and, should they arise, we manage them with a sense of responsibility and transparency. By the term "conflicts of interest", on a non-exhaustive basis, we mean the situation in which the interest – economic, financial, family or otherwise – of a Person within the company interferes or tends to interfere with their ability to make impartial decisions in the best interest of the company itself.

6

Impartiality and non-discrimination

We recognise the importance of avoiding any discrimination based on gender, age, disability, nationality, sexual orientation, ethnicity, religion, opinions, politics and any other form of diversity, and we promote the uniqueness and inclusion of all the People who collaborate, in any capacity, within the company, valuing everyone's contribution in all aspects of our daily activities and in every interaction with others.

7

Loyalty & Trust

Loyalty and trust feed each other and reinforce a climate of "mutual respect" within the company. Loyalty towards colleagues, as well as towards business partners, competitors and authorities, is expressed through correct behaviour based on the principles of professionalism and full cooperation, and respectful of people, institutions and the principles of fair competition. Trust is an expression of security, serenity and appreciation that strengthens the ability to work together and allows the creation of relationships based on transparency.

8

Protection of people

Protecting People and recognising their rights at work are a priority for the company, in full compliance with the current regulatory framework and with the aim of promoting the safety and psychophysical integrity of workers and, more generally, human rights in the conduct of business and company activities.

9

Respect for the environment

We are aware that respect for the environment comes through minimising the impact of production activities upon it, in a perspective of balance between economic initiatives and essential environmental protection needs.

10

Culture of ethical values

We foster a working climate that respects applied Ethical Principles, in the awareness that this reinforces the recognition of and adherence to the company's values among its People and promotes their dissemination towards the third parties who maintain business relationships with it.

The Charter of Ethical Principles is an initiative promoted by the Business Integrity Forum of Transparency International Italia and the companies that have joined it.

The Charter of General Ethical Principles is published under a Creative Commons Attribution – Non Commercial – No Derivatives 3.0 Italy licence, which permits sharing and reuse subject to attribution to Transparency International Italia and sharing under the same terms.

The Company undertakes to adopt and respect the “Charter of Ethical Principles” of Transparency International Italia.

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