Organizational Model, Code of Ethics and Whistleblowing

The Code of Ethics of S2C, in compliance with Legislative Decree n. 231/01, has been in force since 29 September 2010.

The model is an operational tool that translates ethical criteria into principles and rules of conduct. It aims to formulate rules of conduct that must be respected by employees and operators with whom the company comes into contact.

The Supervisory Committee (SC) of S2C, appointed by the Board of Directors, was established with the task of supervising the functioning and compliance of the Organizational and Management Model and to ensure continuous monitoring in order to avoid that criminal acts or offenses are committed, whether in interest and / or to the benefit of the Company, that are prohibited by Legislative Decree n. 231/01.

Current SC members are:

• - Dr. Nicola Fiore
    Piazza Velasca 8 - 20122 Milan, Italy; tel. +39 02/76014305;
• 
  
• - Dr. Eugenio Mittiga
    Via Ceresio 7 - 20154 Milan, Italy; tel. +39 02/32169300

Both members are professional experts outside the Company: therefore effective independence is guaranteed including the autonomous powers of initiative and supervision.

For suggestions and / or requests to be submitted to the SC, there is an active and dedicated email account. Please submit any suggestions and / or requests to the SC to our dedicated mailbox: odv@s2cspa.it.

S2C, in accordance with Legislative Decree No. 24/2023, has established specific procedures by which employees or third parties (e.g., suppliers, customers, etc.) can confidentially and securely report any administrative, accounting, civil, or criminal violations, as well as breaches of Model 231 and the Private Insurance Code, encountered during the performance of their duties (known as Whistleblowing).

S2C has appointed attorney Paolo Orsenigo and Dr. David Roland Zemp as managers of the reporting channel. These independent professionals possess the necessary competencies and ensure the confidentiality of the whistleblower's identity.

Reports can be made to the manager of the reporting channel by choosing from several methods:

• - In writing, by sending a message through the access link at https://s2c.integrityline.com; the platform accessed through this link is managed exclusively by the reporting channel manager, is outside the control of S2C, and without any possibility of direct or indirect access and control by S2C staff;
• - Orally, directly by calling the managers of the channel (attorney Paolo Orsenigo at +39 02 865394 or Dr. David Roland Zemp at +39 02 29017077 ) or, alternatively, upon the whistleblower's request, through a direct meeting.

In addition to the internal reporting channel mentioned above, it is possible to make reports to the external channels provided by D.Lgs No. 24/2023.