ORGANIZATIONAL MODEL 231

The Legislative Decree of June 8, 2001, titled "Discipline of the administrative responsibility of legal persons, companies and associations, including those without legal personality" ("Decree"), introduced in the Italian legal system a special regime of administrative responsibility for Entities for certain offenses committed, in the interest or to the advantage of the same: by directors, managers or employees. This liability is in addition to that of the natural person who materially carried out the act.

The Company Eudaimon Spa, sensitive to the need to ensure conditions of fairness and transparency in the conduct of business and corporate activities, to protect the expectations of its Stakeholders and the work of its employees, in accordance with the provisions of art. 6 of the Decree, has adopted an Organization and Management Model ("Model") aimed at preventing the commission of the different types of offenses contemplated.The Model, published, for the sake of transparency, in this section, aims to regulate the conduct of the parties involved, through the construction of a structured set of rules of conduct, protocols and procedures.

THE CODE OF ETHICS

An integral part of the Model is the "Code of Ethics" (also published in this section) in which the values that inspire Eudaimon in the conduct of its business and the achievement of its objectives are defined, including for the purpose of preventing the crimes provided for in the Decree.For the concrete and effective implementation of the Model and compliance with the Code of Ethicshas been established a Supervisory Board ("SB"), with operational autonomy, to which the Company has entrusted the task of supervising the operation and compliance with the Model, as well as to take care of its updating.

The SB, which is external to the Company, can be contacted at the dedicated e-mail address odv231@eudaimon.it

WHISTLEBLOWING

Legislative Decree 24 of March 10, 2023 headed "the protection of persons who report violations of Union law and containing provisions regarding the protection of persons who report violations of national regulatory provisions, " transposed into the Italian legal system the EU legislation (EU Directive 2019/1937) for the protection of individuals who report illegal activities or fraud within a public or private work context and which harm the public interests or the integrity of the entities to which they belong ("Whistleblowing legislation").

In compliance with the provisions of the law, Eudaimon S.p.A. has made available to employees and collaborators the possibility of reporting, even anonymously, offenses and/or violations, of which they have become aware.

The objective is to prevent the realization of non-compliance or irregularities within the organization, but also to involve all stakeholders, in an activity to combat illegality, through active and responsible participation.

All behaviors, acts or omissions that harm the public interest or the integrity of the Company and of which one has become aware in the work context may be reported, as they constitute:

• unlawful conduct relevant under Legislative Decree No. 231/2001 or violations of the Organization, Management and Control Models adopted under Legislative Decree No. 231/2001;

• offenses within the scope of European Union acts relating to, but not limited to, the following areas: public procurement; services, products and financial markets and prevention of money laundering and financing of terrorism; product safety and compliance; environmental protection;

• acts or omissions affecting the financial interests of the European Union and/or affecting the internal market.

• violations of gender equality and the provisions of UNI/PDR 125 certification.

The report may be made through the internal channel made available by Eudaimon S.p.A. and in the manner set forth in the appropriate"Whistleblowing Policy", and will be handled in accordance with it.

Reports are received by the Supervisory Board guaranteeing the confidentiality of the Whistleblower. The performance of the investigative activity may include the involvement of other competent corporate Functions/Facilities/Bodies and/or the collaboration of external third parties, always in compliance with confidentiality obligations as provided for by the regulations. Notwithstanding the preferential use of the internal reporting channel, pursuant to Article 6 of Legislative Decree 24 of March 10, 2023, it is also possible to report to the relevant authority (ANAC).

The Whistleblower may not be sanctioned, dismissed, demoted, replaced, transferred or subjected to any other unfavorable measure for reasons directly or indirectly related to the reporting.

SUSTAINABILITY, QUALITY AND ENVIRONMENT

Eudaimon is aware of the importance of the social contribution of business activity and intends to pursue the pursuit of market competitiveness through the correct and functional use of its resources, going beyond compliance with merely economic requirements and in full respect for the quality of the environment and the social system, also in order to increase its ability to produce value and create well-being for the community.

In this context, Eudaimon has set precise goals to achieve results of excellence. These goals, which are the basis of the Integrated Management System implemented in Eudaimon, are formalized in the "Quality and Environmental Policy" document available and viewable in this section.

IMPACT REPORT

Since 2021, Eudaimon S.p.A. has been transformed into a Benefit Society (SB), embracing an even more evolved way of doing business and embarking on a path of further growth and commitment to sustainability and inclusiveness goals in order to bring concrete benefits to the reality in which it falls and, in general, to those around it. After its transformation into a Benefit Society, Eudaimon continued its evolutionary process by obtaining B Corp certification at the beginning of 2023.

The objectives identified as well as the measurement of their degree of achievement are formalized within the Impact Report, a document through which Eudaimon commits to chronicle the progress of the objectives included in the charter and to find new ways to personally commit to a sustainable future.

CODE OF CONDUCT FOR SUPPLIERS

Eudaimon is aware that a company's success is measured through a combination of multiple factors, not just economic, and places great emphasis on ensuring that its activities are carried out with integrity and professionalism, pursuing high ethical standards and complying with local and international regulations.

Suppliers are a fundamental and essential part of Eudaimon's business and therefore, for any strategy or path, their participation is necessary.

The Code of Conduct is addressed to all those who work in collaboration with Eudaimon and aims to define the guidelines of behavior to be adopted every day in the management of their work activities

UNI/PdR 125:2022 CERTIFICATION - GENDER EQUALITY.

At Eudaimon, we are committed to incorporating the principles of gender equality, articulated over the entire career path and life stages of female workers, from recruiting to retirement, with the aim of not only increasing the presence of women within the work environment but also ensuring equal career opportunities, up to the most important apical roles, equal economic treatment, work-life balance conditions appropriate to the different stages of life and proactive in the rebalancing of family loads between men and women, as well as a work environment that rejects stereotypes, discrimination, all forms of physical, verbal, and digital abuse and instead proposes a culture of diversity and inclusion.

The UNI/PdR 125:2022 reference practice is not a national standard, but it is a document published by UNI (an Italian standardization body), as required by EU Regulation No. 1025/2012, reflecting the outcomes of the discussion held in the Working Table on Gender Certification of Enterprises provided for in PNRR Mission 5, coordinated by the Department for Equal Opportunities and attended by the Department for Family Policies, the Ministry of Economy and Finance, the Ministry of Labor and Social Policies, the Ministry of Economic Development, and the National Equality Council.

The Reference Practice defines guidelines on the management system for gender equality, which provides for the structuring and adoption of a set of performance indicators (KPIs) inherent in gender equality policies in organizations.

The Reference Practice for Gender Equality in Organizations provides for the measurement, reporting and evaluation of gender-related data in organizations with the aim of closing the gaps that currently exist as well as incorporating the new paradigm related to gender equality into the DNA of organizations and producing sustainable and lasting change over time.

RELATED DOCUMENTS

• Model 231 (Italian only)
• Code of Ethics  (Italian only)
• Quality and environmental policy  (Italian only)
• Impact reports  (Italian only)
• Code of conduct for suppliers  (Italian only)
• Gender Equality Policy  (Italian only)
• Appointment Gender Equality Steering Committee  (Italian only)
• Appointment Gender Equality Officer  (Italian only) (Italian only)
• Gender Equality Strategic Plan