With a resolution of 25th March 2011, the Board of Directors of Lamberti S.p.A. approved an updated version of its Model of "organization, management and control" in accordance with legislative decree 231/2001 (henceforward the "Model").

The Model is an internal regulation of the Company, which formalizes a structured, organic system of organizational and control procedures and protocols, aimed at preventing the committing of crime and at rendering the existing control and governance system more effective.

In addition, the Code of Ethics of the Lamberti Group (henceforward the "Group") approved with the resolution of 15th December 2010 and which constitutes an essential basis of the Model itself, remains in force.

The purpose of the Code of Ethics is to state the rules of conduct which the Group places at the base of the running of its affairs, in order to spread within its business reality those values and rules of conduct to which the Group constantly makes reference and which aim at the pursuit of an ethical culture and the transparency of the company.

Consequently the adoption of the Code of Ethics aims to meet the needs and expectations of all the internal and external parties which the Group deals with. In this regard it is emphasised that in no way may the pursuing of the company's interest disregard compliance with the regulations in force and the content of the Code.

The Code of Ethics is subdivided into three sections:

• Charter of Ethics: formalises the Values, Vision and Mission which constitute the foundations of the Group culture;
• Rules of Conduct: highlights the areas of responsibility and the conduct to adopt in order to be compliant with the Group's style;
• Rules of Conduct: highlights the areas of responsibility and the conduct to adopt in order to be compliant with the Group's style;