Code of Ethics

(Pursuant to Legislative Decree 231/2001)

1. Introduction

ZEN CARBURANTI SRL adopts this Code of Ethics as an integral part of its Organization, Management and Control Model, in compliance with Legislative Decree 231/01, to prevent the commission of crimes and promote a corporate culture based on integrity, transparency and responsibility.

2. Fundamental Principles

The company is committed to respecting the following fundamental principles:

• Legality: Compliance with applicable national and international laws and regulations.
• Integrity and Transparency: Fairness and clarity in relationships with customers, suppliers, employees and stakeholders.
• Responsibility and Sustainability: Commitment to protecting the environment, health and safety at work.
• Confidentiality and Data Protection: Protection of sensitive and confidential information of the company and the parties involved.
• Fair Competition: Promotion of a fair and competitive market, without unfair practices.

3. Scope of Application

The Code of Ethics applies to:

• Members, directors and managers
• Employees and collaborators
• Suppliers, customers and business partners
• All those who operate in the name and on behalf of the company

4. Rules of Conduct

4.1 Relations with Customers and Suppliers

• Ensure clarity, correctness and completeness in commercial information.
• Select suppliers according to the principles of quality, transparency and competition.
• Reject any form of corruption or improper behavior.

4.2 Relations with Employees and Collaborators

• Ensure a safe, inclusive and respectful work environment.
• Promote professional growth and value merit.
• Prevent all forms of discrimination and abuse.

4.3 Relations with the Public Administration

• Operate with transparency and correctness in relationships with public bodies.
• Prohibit any form of offering of money or personal benefits to public officials.

4.4 Environmental and Safety Protection

• Take measures to reduce the environmental impact of business activities.
• Ensure compliance with workplace safety regulations.

5. Control and Sanctions System

• Violation of this Code of Ethics entails disciplinary sanctions, in accordance with Model 231 and the employment contract.
• A Supervisory Body (SB) is established to monitor compliance with the Code and receive reports of violations.

6. Reporting Methods

• Anyone who becomes aware of violations can report them to the Supervisory Body through confidential channels, ensuring the protection of the whistleblower.