code of ethics

This Code of Ethics was approved by the sole director of Tuscania Real Estate Srl on
date 08/09/2023

Summary

Foreword

Tuscania Real Estate Srl is aware that the authority of a company is recognized not only
by the competence of its employees and the high quality of service provided to customers, but also
by the attention paid to the needs of the entire community.
The Code of Ethics (hereinafter, also, the “Code”) is a document adopted by that sets out the principles and
rules of conduct whose observance is required by the Company from all its personnel and third parties
in the performance of their activities.
The purpose of this Code is to declare and disseminate the values and rules of conduct to which the Company
intends to refer constantly in the exercise of its business activities.
This Code represents a distinctive and identifying element in relation to the market and
third parties, the knowledge and sharing of which, required of all those who work in the Company or who collaborate with
it, constitute the foundation of our activity and the first step in contributing to the
pursuit of our vision.
Tuscania Real Estate srl’s goal is to pursue excellence in the market in which it operates, through
a Sustainable Development, safeguarding the Environment and People’s Safety, satisfying its
customers and providing added value to all Stakeholders: “Creating Value is our job.”

purpose and target audience

This Code illustrates the set of ethical and moral principles that underlie the activities of
Tuscania Real Estate srl (hereinafter, the “Company”), the lines of conduct adopted by it
within its business (in relations with employees and collaborators) and
externally (with all those who, in any capacity, cooperate and collaborate with the Company, partners
business (i.e. the “Stakeholders”).
This Code is binding for the directors, employees and collaborators of Tuscania Real
Estate srl, as well as for all those who work and collaborate, on a permanent or temporary basis,
on behalf of the Company (hereinafter, the “Recipients”).
The Code will be widely disseminated within the internal governance structure, and widely
communicated externally, including through its website.

GENERAL PRINCIPLES

The conduct of Recipients at all levels of the company is guided by the principles of integrity, fairness and
fair competition, Sponsorships, gifts, gratuities, non-discrimination, confidentiality and
diligence.

1.1 Integrity

The Company believes that compliance with the law, regulations and this Code is a
primary value to be constantly ensured.
The Company provides its customers with quality services in order to efficiently meet
their expectations.

1.2 Fairness and Fair Competition

The Company requires Recipients to operate in accordance with principles of fairness, fair competition and
transparency towards its staff, institutions, suppliers, distributors, customers
and all operators in the market.

1.3 Sponsorships, gifts, donations

The Company is committed to sponsoring only events with corporate, cultural, sports
or charitable value.
It is prohibited for personnel working and operating within the Company to offer and receive gifts, or
other benefits of a nature and value that could be interpreted as aimed at obtaining benefits of
any nature and in any case not in line with normal custom, this value is set within
€ 200.00.

1.4 Non-Discrimination

The Company avoids all forms of discrimination by promoting dialogue, equal opportunity, diversity
and inclusion.

1.5 Confidentiality

The Company is committed to ensuring the protection and confidentiality of personal data in compliance with
any applicable legislation on the subject.
The Recipients are required not to use confidential information, learned in their own activity
work, for purposes unrelated to the exercise of that activity, and in any case to always act in compliance
with the obligations of confidentiality assumed by Tuscania Real Estate srl towards all the Bearers of
Interests.

1.6 Diligence

The relationship between Tuscania Real Estate srl its employees and collaborators is based on mutual
trust, respect and collaboration: employees and collaborators are required to work to further the
interests of the company, in compliance with the values set forth in this Code.
The Recipients of this Code are required to carry out their activities with the diligence required
by the type of assignment, with professionalism and reliability.
If there is any doubt of being in a situation of conflict of interest, even if only potential, the
Recipients shall promptly inform the Company, complying with the decisions taken by the latter.

2. PERSONNEL MANAGEMENT

The Company protects and values its staff by committing to respect their rights.

The Company:
– promotes workers’ participation in the life of the company;
– offers all personnel equal opportunities, so that everyone can enjoy
fair treatment based on meritocratic criteria;
– promotes a culture of health and safety in the work environment;
– ensures a work environment suitable for human, professional and personal growth;
– combats incidents of bullying, stalking, psychological violence and any behavior
discriminatory or damaging to the dignity of the person on and off company premises.

3. TRANSPARENCY AND FAIRNESS IN THE MANAGEMENT OF THE ENTERPRISE

All economic and financial operations and transactions must be recorded, authorized,
correct, truthful. verifiable, legitimate, and congruous.
The Company, in preparing the financial statements and all other corporate communications required by law,
complies with the relevant codified regulations and accounting principles.

3.1 Heritage protection

All company assets must be used responsibly, avoiding any misuse
including by third parties, used and guarded diligently.

3.2 Communication and Use of Information Systems

Tuscania requires compliance with the provisions of corporate information security regulations, in
order not to compromise the functionality and protection of information systems and the data they contain
.
It is forbidden to alter in any way the operation of the computer system or intervene
illegally in any way on data, information or programs contained in a
computer or telematic system even of third parties.
The Company promotes effective corporate communication that can connect the company
with civil society, in order to take in the instances, needs and requirements of the community and spread
its own values and mission.
The advertising promotion of Tuscania Real Estate Ltd. respects ethical values, protecting minors and
repudiating vulgar or offensive messages.

4 EXTERNAL RELATIONS

4.1 Relations with Authorities and Public Administrations.

Relations with the Authorities and the Public Administration must be marked by the utmost
clarity, transparency and cooperation, in full compliance with the law and according to the highest
moral and professional standards.
The Recipients, unless expressly authorized, may not relate in the name and on behalf of
Tuscania Real Estate srl with the Authorities and the Public Administration.

4.2 Relationship with customers, suppliers and partners

Recipients shall deal with third parties with courtesy, competence and professionalism.
Relations with customers, suppliers and partners are marked by loyalty, fairness, transparency and in
respect for equal opportunities to all those involved.

5 CONTROL SYSTEM

Compliance with the requirements of this Code is entrusted to the prudent, reasonable and careful
supervision of each of the Recipients, within the scope of their respective roles and functions within
the company.
Any violation, actual or even only potential, committed in to what is indicated in this
Code of Ethics and the Model may be reported by the Recipients directly to the ‘Administrator.

6 PENALTY SYSTEM

Violation of the aforementioned rules constitutes a breach of the obligations arising from the
employment relationship and/or a disciplinary offence, with all legal consequences, i.e. the application of disciplinary sanctions
in accordance with the current provisions of law and collective agreements applicable to the Company,
including with regard to the preservation of the employment relationship, and may entail the obligation to pay compensation
for damages arising from the violation committed.
Violation of the rules of the Code by persons external to the Company may entail, in
more serious cases, termination of the contractual relationship.

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