PREMISE

THE VISION OF MUTA SRL

Muta srl is aware that the authority of a company is recognised not only by the competence of its staff and the high quality of the service provided to customers, but also by the attention paid to the needs of the entire community.

The principles that have always inspired the work of this Company are formally set out in an Ethical Code of Conduct in the belief that reliability is built on a daily basis by respecting the rules and valuing people.

This Code of Ethics therefore 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 collaborate with it, constitute the foundation of our activity and the first step towards the pursuit of our vision.

Muta srl's objective is therefore to pursue excellence in the market in which it operates, through Sustainable Development, safeguarding the Environment and the Safety of the people involved through consistent behaviour that respects Social Ethics, to achieve satisfaction and ensure added value for the Employee, the Customer and, in general, for the Community.

PURPOSE AND TARGET AUDIENCE

This Code of Ethics (hereinafter, the "Code") illustrates the set of ethical and moral principles that underlie the activities of Muta srl (hereinafter, the "Company") as well as the lines of conduct adopted by the Company both internally (in relations between employees) and externally (in relations with institutions, suppliers, customers, business partners, political and trade union organizations as well as the media (hereinafter, the "Stakeholders").

Respect for these principles is of fundamental importance to achieve Muta srl's corporate mission and to guarantee its reputation in the socio-economic context in which it operates.

First of all, it should be noted that the company firmly believes that every activity must be carried out ethically, recognizing the principle enshrined in Article 41 of the Constitution, according to which private economic initiative "may not be carried out in conflict with social utility or in such a way as to damage security, freedom and human dignity".

This Code is binding for the directors and employees of Muta srl, as well as for all those who operate and collaborate, on a permanent or temporary basis, on behalf of the Company (hereinafter, the "Addressees").

The Code will be widely disseminated within the internal governance structure, and widely communicated externally, including through its own website.

Muta srl also undertakes to adopt any further provision so that the principles and provisions of the Code may be promptly disseminated and applied.

1. GENERAL PRINCIPLES

The conduct of the Addressees, at all company levels, is based on the principles of legality, fairness, non-discrimination, confidentiality, diligence and loyalty.

1.1 Legality

Muta srl operates in absolute compliance with the law and this Code.

All Addressees are therefore obliged to comply with all applicable regulations and to constantly update themselves on legislative developments, also by taking advantage of the training opportunities offered by Muta srl.

The Company considers transparency in financial statements and accounting to be a fundamental principle for the conduct of its business and for the protection of its reputation.

1.2 Correctness

Fairness and moral integrity are an unfailing duty for all Addressees.

Recipients are required not to establish any privileged relationship with third parties that is the result of external solicitations aimed at obtaining improper advantages.

In the performance of their activities, Addressees are required not to accept donations, favours or benefits of any kind (except for items of modest value) and, in general, not to accept any consideration in order to grant advantages to third parties in an improper manner.

In turn, the Addressees must not make donations of money or goods to third parties or in any case offer unlawful benefits or favours of any kind (except for objects of modest value or commercial courtesy gifts authorized by the Company) in connection with the activity they carry out for the benefit of Muta srl.

The intrinsic conviction of acting in the interest of the Company does not exonerate the Addressees from their obligation to comply with the rules and principles of this Code.

1.3 Non-Discrimination

In its relations with Stakeholders and, in particular, in the selection and management of personnel, in the organisation of work, in the choice, selection and management of suppliers, as well as in its relations with Bodies and Institutions, Muta srl avoids and repudiates any discrimination regarding the age, sex, race, sexual orientation, state of health, political and trade union opinions, religion, culture and nationality of its interlocutors.

At the same time, Muta srl fosters integration, promoting intercultural dialogue and protecting the rights of minorities and the weak.

1.4 Confidentiality

Muta srl undertakes to ensure the protection and confidentiality of the personal data of Recipients and Stakeholders, in compliance with all applicable legislation on the protection of personal data.

Recipients are required not to use confidential information, acquired because of their working activity, for purposes unrelated to the exercise of that activity, and in any case to always act in compliance with the confidentiality obligations assumed by Muta srl towards all stakeholders.

In particular, the Addressees are required to maintain the utmost confidentiality with regard to documents revealing know-how, transport information, commercial information and corporate operations.

1.5 Diligence

The relationship between Muta srl and its employees is based on mutual trust: employees are therefore required to work in the interests of the company, in accordance with the values set out in this Code.

The Addressees must abstain from any activity that may conflict with the interests of Muta srl, renouncing the pursuit of personal interests that conflict with the legitimate interests of the Company.

In cases where the possibility of a conflict of interest may arise, the Addressees must contact their superior ,without delay, so that the company can assess, and possibly authorize, the activity potentially in conflict.

In cases of violation, the Company will take all appropriate measures to put an end to the conflict of interest, reserving the right to take action to protect itself.

1.6 Loyalty

Muta srl and the Addressees are committed to a fair competition, in compliance with national and Community legislation, in the awareness that virtuous competition is a healthy incentive for innovation and development, and also protects the interests of the consumers and the community.

2 RELATIONS WITH EMPLOYEES AND COLLABORATORS

2.1 Staff selections

Staff assessment and selection are carried out in a fair and transparent manner, respecting equal opportunities in order to match Muta srl's needs with the professional profiles, ambitions and expectations of the candidates.

Muta srl undertakes to adopt all useful measures to avoid any form of favoritism in the personnel selection process, using objective and meritocratic criteria, with respect for the dignity of the candidates and in the interest of the smooth running of the company.

Recruited staff, including through the implementation of this Code, receive clear and correct information about the roles, responsibilities, rights and duties of the parties involved.

2.2 Staff management

Muta srl protects and enhances its human resources, committing itself to maintaining the necessary conditions for the professional growth, knowledge and skills of each person, carrying out the appropriate training for professional updating and any initiative aimed at pursuing this goal.

Muta srl promotes the participation of workers in the life of the company, providing participatory tools that can collect the opinion and suggestions of workers, ensuring their widest participation.

Notwithstanding the maximum availability towards the Company, no employee may be obliged to perform tasks, services or favors that are not due according to his contract of employment and his role within the company.

The Company is firmly committed to combating episodes of mobbing, stalking, psychological violence and any discriminatory behavior or behavior detrimental to the dignity of the person in and outside company buildings.

Relations between employees must be conducted with loyalty, fairness and mutual respect, in accordance with the values of civil coexistence and the freedom of individuals.

3 WORK ENVIRONMENT

Muta srl is committed to providing its staff with a healthy, safe and dignified working space.

Safety in the workplace is ensured both by strictly implementing the dispositions foreseen by the law in force and by actively promoting a safety culture through specific training programs. Staff training is a central element of the management system adopted.

Muta srl safeguards the health of its workers, guaranteeing compliance with hygiene and health prevention regulations.

4 BUSINESS MANAGEMENT

4.1 Compliance with internal procedures

Muta srl is convinced that management efficiency and a culture of control are indispensable elements for the achievement of its targets.

The Addressees are required to rigorously comply with the company's internal procedures and instructions.

Addressees must act in accordance with their authorization profiles and must keep all appropriate records to keep track of actions taken on behalf of the company.

4.2 Account management

In the activity of accounting management, the Addressees are required to work in compliance with the principles of truthfulness, accuracy and transparency, in order to protect the reputation of Muta srl both internally and externally.

Respecting these principles also enables the company to plan its business strategies on the bases of its real economic and financial situation.

All the items shown in the accounts must therefore be supported by complete, clear and valid documentation, avoiding any form of omission, falsification and/or irregularity.

In the case of balance sheets or income statements based on valuations and estimates, the recording of these must be based on criteria of rationality and prudence.

4.3 Heritage protection

Addressees exercise their functions by trying to rationalize and contain the use of company resources.

Addressees are required to the correct application of security provisions in order to protect hardware devices from non-authorized access, which could seriously infringe the personal data protection rights of Muta srl's staff and customers.

4.4 Communications

Muta srl provides Stakeholders with proper communication tools through which they can interact with the company to forward requests, require clarifications or make complaints.

Muta srl promotes effective corporate communication that puts the company in contact with civil society, in order to take charge of the instances, needs and requirements of the community and to disseminate its values and mission.

The informations disseminated to Stakeholders are complete and accurate in order to allow the addressees to make correct and conscious decisions.

Muta srl's advertising promotion respects ethical values, protecting minors and rejecting vulgar or offensive messages.

5 EXTERNAL RELATIONS

5.1 Relations with Authorities and Public Administrations

Relations with the Authorities and the Public Administration must be based on the utmost clarity, transparency and cooperation, in full compliance with the law and according to the highest moral and professional standards.

Unless expressly authorized, the Addressees may not deal in the name of and on behalf of Muta srl with the Authorities and the Public Administration.

In relations with Public Officials, Persons in Charge of a Public Service, and the Public Administration in general, the authorized Addressees shall abide by the highest levels of correctness and integrity, refraining from any form of pressure, explicit or veiled, aimed at obtaining any improper advantage for themselves or for Muta srl.

In this regard, the authorized Addressees shall strictly comply with the provisions of this Code, as well as, more generally, with the directives issued by the management of Muta srl.

5.2 Relations with Political and Trade Union Organization

Muta srl does not favor or discriminate against any political organization or trade union.

The Company refrains from making any undue contribution in any form whatsoever to political parties, trade unions or other social formations, except in the case of specific exceptions and in any case always within the limits of what is permitted by the norms in force.

Addressees are required to avoid any direct, indirect or brazen pressure on political representatives or trade union representatives.

5.3 Relations with Customers and Suppliers

The Addressees interact with third parties in a courteous, competent and professional manner, in the conviction that the protection of the company's image and reputation and consequently the achievement of the company's objectives depend on their actions.

In particular, Addressees shall refrain from any form of unfair or deceptive behavior that may induce customers or suppliers to rely on unfounded facts or circumstances.

The Addressees shall constantly strive to offer timely and high quality services to customers, trying to limit any form of inefficiency or delay in order to maximize customer satisfaction.

Relations with suppliers are based on fairness, correctness and transparency.

Suppliers are chosen on the basis of objective criteria of economy, expediency and efficiency.

Suppliers may not be chosen on purely subjective and personal bases or, in any case, on the basis of interests that conflict with those of the company.

Recipients must put in place all possible controls to ensure that suppliers and customers are also able to comply with the fundamental ethical principles set out in this Code.

6 INTERNAL CONTROL SYSTEM

The observance of the provisions of this Code is entrusted to the prudent, reasonable and careful supervision of each of the Addressees, within their respective roles and functions inside the company.

All Addressees are invited to report to their direct superiors facts and circumstances potentially in conflict with the Code's principles and prescriptions.

The management of Muta srl and the relevant organs in charge shall take all necessary measures to put an end to violations, being able to use whatever disciplinary measures in compliance with the law and workers' rights, including trade union rights.

7 GUIDELINES FOR THE SANCTIONS SYSTEM

The internal control system is oriented towards the adoption of tools and methodologies aimed at countering potential business risks, in order to ensure compliance not only with the law, but also with internal dispositions and procedures.

In fact, the violation of the principles set out in the Code and in the procedures indicated in the internal controls compromises the trust relationship between the Company and its directors, employees, consultants, collaborators in various capacities, customers, suppliers, commercial and financial partners.

Such violations will therefore be immediately persecuted by Muta srl in an incisive and prompt manner, through the adoption of appropriate and proportionate disciplinary measures.

The effects of violations of the Code of Ethics and internal protocols must be taken into consideration by all those who, for any reason, have relations with Muta srl. Depending on the gravity of the conduct of the person involved in one of the unlawful activities envisaged by the Code, Muta srl will take the appropriate measures without delay, regardless of whether or not criminal proceedings are brought by the judicial authorities.

In addition to the above, behavior in breach of the Code of Ethics constitutes are:

1. or serious breach for employees (blue-collar workers, white-collar workers, middle managers and executives), with the sanctions, applied depending on the seriousness of the breach, provided for in the CCNL for the category (verbal reprimand, written reprimand, fine not exceeding three hours' pay, suspension from work and from pay up to a maximum of three working days, dismissal for just cause or justified reason); if criminal proceedings are pending or if a measure restricting personal freedom is taken against the employee, before adopting the disciplinary measure, the sanction of suspension from service and from pay may be adopted, for the duration corresponding to the outcome of the criminal proceedings or until the end of the duration of the measure restricting personal freedom;
2. or just cause for revocation of directors ;
3. or cause of immediate termination of the cooperation, in the most serious cases, for external collaborators and para-subordinates
4. or cause for immediate termination of the work relationship, in the most serious cases, for suppliers, contractors and subcontractors

The identification and application of sanctions shall always take into consideration the general principles of proportionality and of adequacy with regard to the violation in question.

In all the aforementioned cases, Muta srl also reserves the right to exercise all the actions it deems appropriate to claim compensation for the damage suffered as a result of behaviour in violation of the Code of Ethics.

This Code of Ethics has been approved by the Board of Directors of Muta srl