POLICY FOR THE PREVENTION OF CORRUPTION

The Vigilpol Società Cooperativa arl Supervisory Institute believes it is appropriate to implement all necessary measures to prevent any act or behavior that could lead to corruption.

In this regard, it guarantees compliance with current regulations, both in relations with the Public Administration and in relations between private individuals, observing and implementing its own Organizational Model pursuant to Legislative Decree 231/2001 and the Anti-Corruption Management System updated pursuant to the new UNI ISO 37001:2025 standard.

This Policy, together with the Company's Code of Ethics, contributes to increasing the overall level of compliance with applicable regional, national and international laws, regulations and best practices.

To ensure this, the Vigilpol Surveillance Institute diligently implements the following preventive measures:

• It absolutely prohibits behaviors that could be considered corruption or attempted corruption or incitement to corruption;
• It personally respects and requires compliance with current legislation regarding the prevention and fight against corruption, throughout the Italian territory in which it operates, by all employees, collaborators, partners, business associates and suppliers;
• Identifies areas of potential risk and identifies and implements appropriate actions to mitigate these risks;
• It is committed to meeting the requirements of the anti-corruption management system, ensuring its constant implementation and the pursuit of continuous improvement;
• Vigilpol encourages the reporting of suspicions in good faith, based on reasonable and confidential belief, without fear of retaliation. To this end, following the implementation of the whistleblowing legislation with Legislative Decree no. 24 of March 10, 2023, a whistleblowing channel was created for reporting any suspicious events. The reporting channel, accessible through the Istituto Vigilpol corporate website at https://www.vigilpol.it/policy, is designed to guarantee the confidentiality of the whistleblower, protecting their anonymity and providing protection from any retaliatory or discriminatory action. The system is designed to be accessible, fair, and inclusive, usable by all workers and stakeholders, regardless of gender, age, origin, language, ability, or personal status.
• It promotes awareness among business partners involved in sensitive activities, asking for acceptance of the policy and acceptance of the controls required by the anti-corruption management system;
• Promotes ongoing training and information for staff, collaborators, customers, and suppliers on policies, the anti-corruption system, and significant regulatory updates;
• It promotes awareness among staff and collaborators so that they are able to recognize a corrupt event or even just an attempt and can report it, even anonymously;
• requires all staff and collaborators to report to the Corporate Anti-Corruption Function for any issues related to corruption and the management system. The Anti-Corruption Officer is an external, independent figure, i.e., not involved in the organization's activities exposed to the risk of corruption, with appropriate expertise, delegated authority, and tasked with overseeing the design and implementation of the management system;
• informs that failure to comply with the policy may result in the application of the company's sanctions system.

The Vigilpol Supervisory Institute, Società Cooperativa arl, is committed to continuously improving its Corruption Prevention Management System and guarantees the authority and independence of the Corruption Prevention Function (FPC), appointed by Senior Management, with operational independence from the corporate functions it supervises. Those who act on behalf of the Vigilpol Supervisory Institute are aware that, in the event of corrupt behavior and violations of the laws on corruption, they may incur offenses punishable not only by criminal and administrative law, but also by corporate disciplinary action.

The Senior Management of the Vigilpol Supervisory Institute guarantees the widest possible dissemination of this Policy, ensuring that it is understood and implemented by all employees; to this end, it is also made available on the Company's institutional website.

The Vigilpol Società Cooperativa arl Supervisory Institute also requires its business partners to comply with applicable anti-corruption laws, the Code of Ethics, and this Policy. It also requires training and awareness-raising on corruption prevention, as required by the ISO 37001:2025 standard, based on clauses whose non-compliance entails termination of the contract.