The Code of Ethics of Studio Informatica Srl can be defined as the company’s "Constitutional Charter," a declaration of rights and duties that defines the ethical-social responsibility of every participant in the business organization. The Code of Ethics was created to ensure that the ethical values which Studio Informatica Srl adheres to and in which its management believes are clearly defined and constitute the foundation of the company culture, as well as the standard of behavior for all employees and collaborators in the performance of their duties. The Code of Ethics also has the specific function of promoting and ensuring correctness and fairness in the management of transactions and human relationships both within and outside the company, with the result of increasing the company's credibility. Therefore, the recipients are required to respect the values and principles of the Code of Ethics and are obligated to safeguard and preserve the reputation and image of Studio Informatica Srl as well as the integrity of its economic and human assets through their behaviors.

Considering the sector in which it operates, Studio Informatica Srl has deemed it appropriate to adopt a set of rules, both internally and in its relations with third parties, aimed at promoting a solid ethical integrity and strong awareness of laws and behavioral rules at all company levels.

Studio Informatica Srl promotes a series of principles that guide the activities of the company, its employees, and all those collaborating with the company, containing the behavioral rules these individuals are required to observe.

These principles are clearly outlined in this Code of Ethics.

Studio Informatica Srl, determined to ensure maximum correctness in conducting its business, in addition to criteria of loyalty, legal compliance, and efficiency, has chosen to comply with the provisions of Legislative Decree no. 231/01.

Studio Informatica Srl is aware that adopting a Code of Ethics, which clearly and transparently outlines the values guiding the company in achieving its interests, is essential for protecting its reliability, reputation, and image, and for increasing customer satisfaction.

1.1 Recipients

The Code of Ethics is intended for the sole director, auditors, employees, and all collaborators of Studio Informatica Srl (all these individuals will be referred to as “recipients of the Code”; Studio Informatica Srl will be referred to as “the company”; employees and collaborators will collectively be referred to as “staff”). The recipients of the Code are required to comply with its provisions and ensure its enforcement. The application of the Code of Ethics within the company integrates, but does not replace, the legislation in force at the time of its adoption by the company’s shareholders.

2. GENERAL PRINCIPLES

This Code of Ethics outlines the guiding principles of Studio Informatica Srl and is binding for the behavior of all those who hold representation, administration, or management roles, or who cooperate and collaborate with the company in any capacity, in pursuit of its business objectives.

2.1 Objectives of the Code of Ethics

The Code of Ethics aims to guide the company’s management based on principles of loyalty, professional correctness, completeness and truthfulness of information, respect for the law, and efficiency. It aims to set clear behavioral guidelines to ensure the satisfaction of all stakeholders and the strengthening of the company’s reputation.

2.2 Company Mission

The mission of Studio Informatica Srl is to provide businesses with the necessary technological infrastructure to operate in the global market in real-time, increasing their ability to collaborate with other economic entities. It aims to offer quality services that provide lasting competitive advantages, bringing value to businesses by enhancing the effectiveness and efficiency of their processes. The company combines dynamism, flexibility, innovation, speed, and specific know-how to lead companies to success.

2.3 Company Vision

To achieve the objectives outlined in its mission, Studio Informatica Srl aims to be:

• A company that creates value for its clients by increasing profitability, automating processes, diversifying and expanding markets, monitoring and controlling business procedures.

• A company that creates value for the territory by supporting local economic realities, adapting business models to local needs, and partnering with strategic partners to strengthen and expand its presence in the socio-economic fabric of its operational areas.

• A company that creates value for its personnel by promoting professional development, training activities, skill development, and fostering a corporate culture based on excellence.

2.4 Stakeholders

Studio Informatica Srl maintains ethical relationships with its stakeholders, which include individuals, groups, entities, and institutions with legitimate interests and/or rights related to the company and its activities.

These stakeholders include customers, suppliers, employees, collaborators, public administrations, business partners, and society at large.

2.5 Guiding Values

• Respect for the Person: Studio Informatica Srl respects the rights and cultural, political, and religious identities of those with whom it interacts. It carefully attends to customer needs, values its collaborators, ensures fair negotiations with suppliers, and participates actively in social life.

• Integrity, Fairness, and Transparency: The company adheres to principles of legitimacy, fairness, respect for rules, transparency, clarity, and accuracy in its business activities.

• Equity and Impartiality: Studio Informatica Srl treats all parties—clients, suppliers, employees, and the community—with fairness and equality, adopting the same approach toward all, regardless of their role or relationship with the company.

• Innovation and Efficiency: The company strives to continuously improve its business processes and service quality through optimal resource allocation, appropriate technology, and organizational solutions that balance client satisfaction with efficiency and cost-effectiveness.

• Confidentiality: The company ensures the confidentiality of personal and sensitive data in compliance with current laws.

3. CONDUCT CRITERIA

3.1 General Conduct Criteria

The Sole Director, directors, and all employees and collaborators must act with the utmost correctness and integrity when dealing with third parties, ensuring strict compliance with laws and regulations. All recipients of the Code are also required to maintain confidentiality regarding all business-related information they become aware of during their work, both for the company and its clients.

3.2 Conduct in Business Affairs

• General Norms: In commercial relations, recipients must avoid engaging in conduct that violates the principles outlined in the Code. They must refrain from offering or accepting gifts, benefits, or any other form of utility, whether personal or not, that might suggest improper conduct.

• Customer Relations: Studio Informatica Srl prioritizes maintaining and improving relationships with customers by ensuring loyalty, transparency, professionalism, and confidentiality. The company provides clear and complete information about its products and ensures it avoids engaging in business with entities lacking the necessary integrity.

• Supplier Relations: Studio Informatica Srl manages supplier relations with fairness, professionalism, and trust, evaluating suppliers based on objective criteria such as quality, price, and safety compliance.

• Relations with Public Administration: Only authorized personnel maintain relationships with public administrations, ensuring that they are based on integrity, transparency, and correctness, and prohibiting the offering or acceptance of bribes or other illegal actions.

3.3 Conduct of Employees

• Supplier Selection Criteria: The company promotes and safeguards the value of human dignity, ensuring fairness in hiring processes, career advancement, and professional development without discrimination.

• Employee Relations: Employees are encouraged to adhere to the principles of the Code, report violations, collaborate in investigations, and respect confidentiality regarding sensitive company information.

4. IMPLEMENTATION MECHANISMS

4.1 Communication and Dissemination of the Code of Ethics

Studio Informatica Srl promotes the dissemination and understanding of the Code of Ethics among all recipients, ensuring its availability to new employees and business partners.

4.2 Reporting Violations

Employees and collaborators must report any violations of the Code to the designated company representative or the Supervisory Board, which will investigate and take necessary actions.

4.3 Disciplinary System

Violating the Code of Ethics constitutes a disciplinary offense and may result in sanctions, in compliance with legal and contractual regulations. Violations by collaborators or external partners may lead to the termination of contracts or assignments and compensation for any damages.

This document outlines the ethical framework and the standards of conduct that guide Studio Informatica Srl’s business operations. It emphasizes integrity, respect, fairness, and legal compliance across all activities within the company.