Organizational Model and Code of Ethics

Pizeta Pharma S.p.A. has always pursued a corporate philosophy based on business values, managing its activities according to the principles of efficiency, fairness, and loyalty in every aspect of its daily work.

Pizeta Pharma S.p.A. has adopted the Organization and Management Model pursuant to Legislative Decree no. 231/2001, which introduced a system of administrative/criminal liability for companies regarding certain types of offenses provided for by the same Legislative Decree 231/01, thus adapting and integrating its organizational system to the requirements of this regulation.

The adopted Model consists of a series of elements: assessment of potentially risky activities; principles, rules, and codes of conduct; control tools; control procedures and protocols; training and information activities; disciplinary system; Supervisory Body and information flows. The main purpose of the Model is to ensure the prevention of the commission of crimes provided for by the decree itself.

The Organization, Management and Control Model pursuant to Legislative Decree 231/01 was definitively approved by the Board of Directors of Pizeta Pharma S.p.A. with a resolution dated September 2, 2019.

The principles, provisions, and prescriptions provided by the Model adopted by Pizeta Pharma S.p.A. are binding for directors, employees, and all individuals who, in various capacities, operate on behalf of and in the interest of the Company.

Pizeta Pharma S.p.A. has also adopted a Code of Ethics that defines the set of values that the company recognizes, accepts, and shares, at all levels, in carrying out its business activities. The principles and provisions of the Code of Ethics constitute exemplary specifications of the general obligations of diligence, fairness, and loyalty that characterize the performance of work duties, conduct in the workplace, and the company's activities. The Code of Ethics of Pizeta Pharma S.p.A. was also adopted by the Board of Directors on September 2, 2019.

Furthermore, in compliance with art. 6, paragraph 1, letter b), of Legislative Decree 231/2001, with the same Board of Directors resolution of September 2, 2019, the Company established and appointed its Supervisory Body, endowed with autonomous powers of initiative and control, whose task is to oversee the functioning and observance of the Model, ensuring its updates.

Furthermore, in compliance with the obligations set forth by the "Whistleblowing" regulations, introduced by Law no. 179 of November 30, 2017, concerning "Provisions for the protection of individuals who report crimes or irregularities that they have become aware of in the context of a public or private employment relationship", the Company promotes the prevention and verification of any unlawful conduct or, in any case, conduct contrary to the Code of Ethics and Conduct. Therefore, it encourages Recipients to promptly report to the Supervisory Body of the involved companies any unlawful conduct or, in any case, conduct contrary to the Code of Ethics and Conduct, which they become aware of due to their relationship with the Company. Except in cases of liability for slander or defamation, or for the same reason pursuant to Article 2043 of the Civil Code, the Recipient who, in good faith, reports unlawful conduct or conduct otherwise contrary to the Code of Ethics and Conduct to the Supervisory Body, of which they became aware due to their relationship with the Company, cannot be sanctioned.
No form of retaliation or discriminatory measure, direct or indirect, affecting working conditions for reasons directly or indirectly linked to the report, is permitted or tolerated against Collaborators who make reports within the whistleblowing system introduced by the Company.
The Company also prohibits any form of abuse of the whistleblowing system, carried out through manifestly opportunistic reports and/or made solely for the purpose of harming the reported party or other individuals, as well as through improper use or intentional instrumentalization of the institution.
All reports relevant under the Decree will be directed to the Supervisory Body appointed by the Company which – after evaluating their validity – will transmit them to the competent parties.