ORGANIZATION, MANAGEMENT AND CONTROL MODEL

PURSUANT TO LEGISLATIVE DECREE 231/2001

ZEN CARBURANTI SRL

1.1 Purpose of the Model

1.1 Purpose of the Model

Il presente Modello di Organizzazione, Gestione e Controllo (“Modello 231”) è adottato da LA ZEN CARBURANTI SRL in conformità al Decreto Legislativo 8 giugno 2001, n. 231, per la prevenzione dei reati previsti dal Decreto stesso. Il Modello ha l’obiettivo di promuovere una cultura aziendale basata su integrità, trasparenza e responsabilità, garantendo un sistema di controllo efficace sulle attività aziendali.

1.2 Scope of Application

This Model 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

2. ORGANIZATIONAL STRUCTURE AND GOVERNANCE

2.1 Company Structure

ZEN CARBURANTI SRL operates internationally in the marketing and distribution of petroleum products, including EN590 10PPM, Jet Fuel A1 and Benzina 95. The company is organized with a governance system that guarantees the separation of functions and transparent management of activities.

2.2 Supervisory Body (OdV)

Pursuant to Legislative Decree 231/2001, the company establishes a Supervisory Body (OdV) with the following functions:

• Monitoring the application of Model 231
• Evaluation of the effectiveness and adequacy of the internal control system
• Handling Violation Reports

The OdV acts with autonomy and independence, reporting directly to the administrative body.

3. RISK ANALYSIS AND CRIME PREVENTION

3.1 Risk Mapping

The company has identified the risk areas related to its activities, with particular attention to:

• Corporate crimes (e.g. false corporate communications, obstruction of supervisory activity)
• Crimes against Public Administration (e.g. corruption, extortion, undue inducement)
• Environmental crimes related to the management and distribution of fuels
• Recycling and self-laundering
• Workplace safety crimes

3.2 Prevention Measures

To reduce the risk of crimes being committed, the Model provides for:

• Codified company procedures for the management of risky activities
• Training and awareness of staff on the principles of Legislative Decree 231/2001
• Confidentiality-enhanced breach reporting system

4. CODE OF ETHICS AND DISCIPLINARY SYSTEM

4.1 Code of Ethics

Il Codice Etico di ZEN CARBURANTI SRL stabilisce i principi di:

• Legality and compliance with regulations
• Integrity and transparency in business operations
• Environmental and social responsibility
• Protection of competition and the market

4.2 Disciplinary System

Violation of Model 231 entails disciplinary sanctions, which may include:

• Recall or suspension
• Economic sanctions
• Dismissal for just cause, in the most serious cases

5. MONITORING AND UPDATING THE MODEL

5.1 Effectiveness Verification

The Supervisory Body periodically verifies the effectiveness of the Model and proposes any updates based on the regulatory or organizational developments of the company.

5.2 Updating the Model

Model 231 is updated in the event of:

• Relevant regulatory changes
• Organizational or corporate changes
• Results of the OdV checks

6. REPORTING AND WHISTLEBLOWER PROTECTION

The company adopts a whistleblowing system that allows you to confidentially report any violations of Model 231 or the Code of Ethics. Reports can be sent via:

• Dedicated email
• Private internal channel
• OdV Help Desk

The company guarantees maximum protection of the confidentiality of the whistleblower, in compliance with current legislation.

7. CONCLUSIONS

With the adoption of this Organization, Management and Control Model, ZEN CARBURANTI SRL confirms its commitment to legality, transparency and corporate ethics, ensuring an effective risk prevention system and promoting a culture of responsibility and compliance within the organization.