The Bulloneria Villa Spa a undertakes to apply an Ethical Code in the highest standards of conduct in relations with stakeholders:

• Distributors and Customers – Providing quality services and products at a fair price

• Suppliers – cooperation relationship, ethical procedures in resources selection, negotiations and administration

• Collectivity – social responsibility and compliance with all laws and regulations, regarding employment, safety and environmental protection; Involvement of both Company and Staff in community’s activities.

• Shareholders – achieving goals in accordance with all applicable laws, caution in the acquisition, use, protection and transfer of Company’s assets.

• Employees – fair payments, development, training, health and well-being; Equal opportunities for all employees; Safe and healthy working environment; Respect for employees’s privacy and individual dignity.

PRINCIPLES OF ETHICAL CODE

In order to encourage the highest standards of ethical behavior into the Company, employees and directors must first of all to enforce always respect the ethical principles and roles listed below;

• Honesty – in contact with customers, suppliers, communities, affiliates and employees
• Integrity – Strictly sticking to Ethics Code in all business activities
• Respect – dignity, fairness and equal opportunities
• Trust – teamwork and open and honest communication
• Responsibility – Report violations to the Ethical Code and behavior standards that occurred or alleged without retaliation fear
• Citizenship – respecting all applicable laws and regulations
• Diversity – Promoting a universal culture that respects the differences and support the achievement of Company’s goal to reflect the diversity of our market.

BEHAVIOR STANDARD

All employees and administrators will therefore have to comply with the following ethical code standards.

1 – Gifts, Payments and Favors
Employees will not have to offer or accept gifts, payments, or favors offered with the purpose of obtaining a reward or influencing a decision.

2 -Conflicts of interest
Employees and directors will have to behave with the interest of Bulloneria Villa. Behaviors, actions, or information use that are in contrast with the interests of the Company are forbidden.
Employees should therefore avoid financial, commercial or other type of relationships that may interfere with the interests of the Company or may be in conflict with the performance of their duties.

3 – Relationships with suppliers
In conclusion employees and purchasing managers first of all must comply with purchasing policies and procedures.
Neither purchasing department employees nor other employees should be allowed to execute purchases for personal interests, by means of Villa Bulloneria’s purchasing department.
Purchase Orders – Only a limited number of employees and directors can draw up a purchasing agreements or contracts on behalf of Bulloneria Villa LTD

4 – Compliance with anti-trust laws and regulations
Employees and Directors undertake to comply with all anti-trust laws and regulations.

5 – Compliance with anti-trust laws and regulations
Employees and directors are committed to being in compliance with European and national anti-trust laws and regulations.

6 – Compliance with intellectual property law
Employees and directors therefore undertake to be in compliance with laws regarding patents, copyrights, trademarks, trade secrets, etc. which protect intellectual property rights of corporations and individuals. Copyrighted software that are used by employees for Company’s activities cannot be reproduced, with the exception of copies made for backing-up purposes, or cannot be reproduced by employee for personal use. The use of unauthorized software installed on computers owned or leased by Bulloneria Villa is forbidden.

7 – Owned or confidential information
Employees and directors aren’t allowed to disclose any public or non-public information, including information about commercial transactions, financial results, sales results, employees, Technological status, or other confidential information, to third parties, competitors or media. This needs to be also applied by third party information, suppliers, and other employees.

8 – Compliance with Environmental Standards
Employees and directors have to be in compliance with all environmental laws and regulations and relative policies and procedures of the Company.

9– Safety at work
Employees and directors have to be in compliance with all laws and regulations regarding employment, safety and health and with all of the policies and procedures of the Company.

10 – Safeguarding of assets
Employees undertake to preserve the properties, facilities and equipment of the Company and to use them in a responsible way. Employees aren’t allowed to use equipment, materials and / or supplies belonging to Bulloneria Villa, as well as services of the Company personnel as personal profit.

11 – Holding appropriate accounting records and corporate records
Company policy finally requires full compliance with current laws and regulations on accuracy and completeness of books and accounting documentation.
Establishing hidden or unregistered funds for any purpose is prohibited.
However an internal accounting control system will be put in place to ensure that transactions are recorded in order to allow the processing of the balance sheet in accordance with generally accepted accounting policies and other requirements specified by Bulloneria Villa Spa, and to account for all Company’s assets.

12 – Storage of documentation
So employees and directors will have to comply with the policies regarding the documentation managing of their function (storage and disposal) for legal and regulatory reasons. The departments most affected by these policies are taxation, HR, health and safety, environment, contracts, financial and business structures.

Milan, July 23rd, 2013
The President of the Board
Marcello Doniselli