IMI Code of Conduct and 231 Model

STI has adopted an Organizational, Management and Control Model pursuant to Italian Decree 231/2001 (“231 Model”) to strengthen even more its internal control system and prevent the commissions of crimes punished by Italian Decree 231/2001. Essential part of the 231 Model is IMI Code of Conduct, our guide for how we behave in business. It is essential that we act with integrity and at all times run our business in an ethical way. Integrity is one of our core values and underpins everything we do. It is a cornerstone of our culture. Our Code of Conduct sets out the standards we expect our employees to adhere to. It covers a range of issues including anti-bribery and anti-corruption.