CODE OF ETHICS COGNE ACCIAI SPECIALI SPA

CODE OF ETHICS COGNE ACCIAI SPECIALI SPA Pagina 1 di 13

1. INTRODUCTION This document, which is part of the Organizational Model pursuant to Italian Legislative Decree nr. 231/01, defines the values and principles of conduct relevant to the smooth operation, reliability, compliance with laws and regulations as well as the image of COGNE ACCIAI SPECIALI SPA. It contains the rights, duties and responsibilities of internal and external stakeholders, beyond and independently by regulations requirements. All Recipients 1 who work for the achievement of business objectives, whether in top positions or not, are required to comply with this in business conduct and corporate activities. All those who have business relations with COGNE ACCIAI SPECIALI SPA, such as professionals and contractors who act in the interests of the Company, are required to conform their behavior to the Code of Ethics. All Recipients behavior must be based on the respect of the fundamental principles of honesty, integrity, fairness, transparency, objectivity and respect for the individual, in the pursuit of corporate objectives and in all dealings with people and organizations inside and outside the Company. In no case may the pursuit of the interest of COGNE ACCIAI SPECIALI SPA justify not following an honest behavioral guideline. Therefore COGNE ACCIAI SPECIALI SPA reserves the right to not undertake or to not continue any relationship with anyone who adopts a behavior different from that established in the Code of Ethics. The is available on the corporate internal network and on the company website (www.cogne.com). 2. GENERAL ETHICAL PRINCIPLES 2.1. Compliance Recipients are required to comply with the law or equivalent acts. This principle is valid with reference to the national legislation of any country with which the Company does business. COGNE ACCIAI SPECIALI SPA is committed to conduct its business in compliance with national, EU and international legislation, rejecting any illegal practice. The pursuit of the Company s interest cannot justify in any case failure to comply with the law. Recipients are required to comply with company regulations as they have the express purpose of better enable the ongoing compliance with the law. Recipients are also required to comply with professional ethics and rules of professional conduct. 2.2. Fairness COGNE ACCIAI SPECIALI SPA performs its business providing goods and services of high quality. 1 All individuals and Entities who work for the achievement of business objectives such as Directors, Top Managers, Employees and all those who have relations or commercial collaboration with the Company such as contractors, professionals, etc. Pagina 2 di 13

Recipients are required to comply with professional rules, with particular reference to the duties of care and skill, applicable to transactions carried out for the Company. All Recipients are directly responsible, with reference to the role assigned, of the good performance of the activities, of the achievement of results and of the duty to protect the image of the Company. Each recipient of this Code should be aware that any behavior not in line with the principle of fairness and the, can compromise the integrity and reputation of the Company. 2.3. Transparecy All Company's activities are inspired by the principles of integrity and transparency and are conducted with honesty and sense of responsibility, fairness and in good faith. Recipients are required, therefore, to pursuit transparency in carrying out company's activities with that meaning clarity, completeness and relevance of information, avoiding tricky situations in transactions carried out on behalf of the Company. COGNE ACCIAI SPECIALI SPA and its staff is committed to provide complete, transparent, understandable and accurate information, so that those who wish to maintain business relations with the Company are able to make independent and informed decisions. 3. RULES OF CONDUCT IN RELATIONS WITH PERSONNEL COGNE ACCIAI SPECIALI SPA protects and promotes the value and the development of Human Resources, recognized as an important success factor for the company, and facilitate their full professional fulfillment on the basis of merit. COGNE ACCIAI SPECIALI SPA is committed to avoid all forms of discrimination, particularly discrimination based on race, nationality, sex, age, disability, sexual orientation, political or trade union opinions, philosophical ideas or religious beliefs. COGNE ACCIAI SPECIALI SPA is committed to protect the moral integrity of its employees and guarantee the right to fair working conditions and the respect the person s dignity. Sexual harassment or acts of physical or psychological violence are not tolerate. COGNE ACCIAI SPECIALI SPA repudiates any form of exploitation of labor. COGNE ACCIAI SPECIALI SPA does not tolerate any form of illegal work or of any type of work performance that is not conducted coherently with the regulatory framework regarding the country of reference. It is forbidden the use of any form of employment of foreign workers that staying illegally in the Italian territory, that meaning without working permit, whose working permit has expired, without request of renewal of the working permit before the legal deadline or whose working permit has been revoked or canceled. COGNE ACCIAI SPECIALI SPA considers essential to protect minors against all forms of exploitation and, therefore, prohibits their employment and the use of child labor. The age of workers cannot be less than the legal minimum age allowed in the pertinent country. COGNE ACCIAI SPECIALI SPA is committed to evaluate job applications solely on the basis of merit and professional competence. The evaluation of job applicants is carried out by matching the profiles of the candidates to the needs of the Company in the observance of equal opportunities for all individuals. Recruitment practices, transfer or promotion should not be in any way influenced by offers or promises of money, goods, benefits, facilities or services of any kind. Pagina 3 di 13

At the beginning of the employment relationship each employee must receive accurate information regarding: characteristics of the role assigned, duties and responsibility and tasks to be performed; regulations and wage, relevant standards, procedures and company policies that must be followed. In managing hierarchical relationships, the Company requires that authority is exercised fairly and correctly, by prohibiting any behavior that might be detrimental to the dignity and autonomy of the employee. Everyone should be treated with respect, without any intimidation and respecting their moral personality, avoiding illegal conditioning, hardship, offensive behavior or exclusion within the working environment. The competent departments ensure that the work environment is safe and healthy and free from prejudice. All Employees, Contractors and Professionals must observe a respectful behavior towards corporate assets. The manufacture, possession, distribution, sale or use of alcohol, illicit drugs and / or other substances not authorized/illegal by employees on Company premises is prohibited. Employees privacy is protected in accordance with Italian Legislative Decree no. 196/03. 4. HEALTH AND SAFETY COGNE ACCIAI SPECIALI SPA is committed to pursue its constant health and safety objectives improvement as part of general purpose of the Company. COGNE ACCIAI SPECIALI SPA: commits to spread and consolidate a culture of safety and health at work, developing risk awareness and promoting responsible behavior by all employees; delivers institutional and recurrent training, both at the beginning and at certain times of the employees life ; promotes and implements all initiatives aimed at minimizing the risks and at removing the causes that might jeopardize the safety and health of employees. This objective is pursued with technical and organizational activities, including the introduction of integrated risk management. Recipients must take care of their own health and safety and of that of other people in the workplace, who might incur in the effects of their actions or omissions in accordance with training, instructions and equipment provided by the Company. 5. ENVIRONMENT PROTECTION COGNE ACCIAI SPECIALI SPA intends to ensure full compatibility of its activities with the territory and with the surrounding environment. With this purpose the company is committed to conduct its activities in total respect for the environment in the broadest meaning, and in particular: evaluating the environmental impact of new activities and new production processes; employing in a responsible and conscious way natural resources; developing a constructive cooperation, imbued with utmost transparency and trust, both internally and with the external community and the institutions in the management of environmental issues; maintaining the highest possible levels of safety and environmental protection through the implementation of effective management systems. Pagina 4 di 13

6. CONFLICT OF INTEREST Conflict of interest must be avoided in conducting any activities. Recipients must avoid engaging in or facilitating transactions involving conflicts of interest, real or potential, with the Company. Recipients must avoid engaging in or facilitating any activity that interferes with the ability to take impartial decisions in the best interests of the Company and in accordance with the principles of this Code. Recipients must refrain from selecting suppliers in situations of conflict of interest with the Company, or in situations where they might favor themselves or other companies to the expenses of the interest of COGNE ACCIAI SPECIALI SPA. Recipients must avoid any situation and refrain from any action that could favor a personal interest to the so-called social interest. 7. DONATIONS, GIFTS OR OTHER BENEFITS It is forbidden to offer or give third parties donations, gift or other benefits except those of modest value directly attributable to normal commercial courtesy. It is forbidden to accept donations, gifts, or other benefits (including in the form of sums of money, goods or services) from third parties, directly or indirectly, even in times of holidays, except for gifts of modest value 2 directly attributable to normal commercial courtesy. Such donations should not in any case cause, on the other side or in a third and impartial outsider, raise the impression that they are aimed at obtaining or granting undue advantages, such as to create the impression of illegality or immorality. In no event Recipients can accept money. It is forbidden to solicit the offer, the grant, the acceptance or receipt of gifts of any kind, including those of modest value. It is forbidden to offer gifts in cash or in kind to Top Managers, Officers or Employees of the Public Administration or their family and/or relatives, of Italian or Foreign nationality, except in the case of gifts or benefits of modest value. Recipient who receives gifts or offers of gifts that do not comply with the above must immediately inform, in the case of employee or collaborator, their Supervisor, and in the case of Top Managers or Directors, the Supervisory Body, for adoption the appropriate measures. Recipient that contracts with third parties must ensure that contracts do not require for or entail donations in violation of this Code. 8. ANTI BRIBERY POLICY The Company has adopted the following policy to ensure maximum transparency and fairness in the management of business relations both with public and with private entities. 2 Exceeding the estimated value of 150 Pagina 5 di 13

All those working for COGNE ACCIAI SPECIALI SPA must act in accordance with the principle of reciprocity, under which each trading partner should contribute to the business relationship, creating benefit for both parties. Therefore, for all those who work for COGNE ACCIAI SPECIALI SPA is forbidden to promise or pay sums of money or goods in kind, and to grant benefits of any kind (promises of employment, etc.) in favor of representatives of other companies in order to promote or favor the interests of COGNE ACCIAI SPECIALI SPA. It is forbidden to distribute gifts outside of the provisions of the corporate practice 3 or with the purpose of obtaining favorable treatment in the conduct of any business activity. COGNE ACCIAI SPECIALI SPA prohibits all the Recipients to ask, for themselves or for others, or accept gifts or other benefits, except those of modest value, from suppliers, contractors, competitors, business partners or representatives of other companies. It is also prohibited to sign agreements or contracts that do not comply with applicable laws and enforce a pricing policy which does not permit freedom of choice. 9. RULES OF CONDUCT IN RELATIONS WITH THE PUBLIC ADMINISTRATION In relations with Public Authorities and Organizations or Public Service, COGNE ACCIAI SPECIALI SPA respects rigorously the EU and national legislation and procedures. All relationships with the institutions of the State, the Public Administration and Public Institutions (Ministries and their local offices, boards and companies working in the field of public services, territorial and local authorities, Antitrust, Authority for the Protection of Personal Data, etc.) must be kept in compliance with the law, the Articles of Association and the provisions in this and in strict compliance with the principles of fairness, transparency and efficiency. COGNE ACCIAI SPECIALI SPA s relations with the Public Administration, Public Organizations or Public Service cannot in any way compromise the integrity and reputation of the Company. In order to ensure maximum clarity in relations, contacts with the Public Administration, Public Organizations or Public Service must take place exclusively through corporate representatives or authorized officers or by clearly identified employees and/or collaborators. It is forbidden to offer or promise money, gifts or payment, in any form, directly or indirectly, even through a third person, in order to induce to perform an official act or contrary to official duties to Managers, Directors, officers or employees of the Public Administration, Public Organizations or Public Service, to their relatives or partners. It is forbidden to exert unlawful pressure or promise any object, service, benefit or favor to Managers, Directors, Officers or employees of the Public Administration, Public Organizations or Public Service, to their relatives or partners in order to induce them to perform an act of office or contrary to official duties. It is forbidden any behavior or offer of bribes in order to favor or damage a party in a civil, criminal or administrative proceeding in order to cause direct or indirect benefit to the company. It is forbidden to offer services and payments to employees, suppliers, consultants or other third parties working on behalf of the Company, in the absence of adequate justification in the context of the contractual relationship established with them or in relation to the type of task to be performed. 3 Exceeding the estimated value of 150 Pagina 6 di 13

The only acceptable forms of courtesy must be of modest value and be aimed at promoting the image of the Company or initiatives promoted by it. The forms of courtesy must also be authorized by the Top Management of COGNE ACCIAI SPECIALI SPA and supported by appropriate documentation. In case of business relations with the Public Administration, including participation in public tenders, it is mandatory to always observe the law and correct business practice. It is forbidden to deliberately behave in a way to attempt to mislead the Public Administration. In particular, it is forbidden to use or to present false statements or documents, documents stating the untruth or omitting information, to the Public Administration, with the only aim to achieve, for the benefit or in the interest of the company, contributions, loans or other payments however named granted by the State, by a Public Entity or by the European Union. It is forbidden to use grants, loans, or other payments however named, granted by the State, by a Public Entity or the European Union, for purposes other than those for which they have been assigned. It is forbidden to alter in any way the operation of a computer or electronic system or act illegally in any manner on data, information and programs contained therein or relevant thereto, in order to obtain an unfair profit to the detriment of others. The ban is strengthened if damaged is the State or a Public Entity. It is forbidden to all Recipients to engage, directly or indirectly, in any illegal action that can favor or damage one of the parties in the course of civil, criminal or administrative. It is forbidden to engage in unlawful coercion 4 or undue pressure 5 in order to induce persons not to make statements or to make false statements before the Court in the criminal proceedings, when they have the right to remain silent. In case of violation of the standards of conduct above described, the Company will not start or continue any relationship with company representatives, contractors, suppliers or partners who do not fall in line with the principle of strict compliance with applicable laws and regulations in all countries where the company operates. 10. RULES OF CONDUCT IN RELATIONS WITH CONSULTANTS AND BUSINESS PROFESSIONALS COGNE ACCIAI SPECIALI SPA selects collaborators and consultants with absolute impartiality, autonomy and independent judgment without accepting any conditions or compromise of any kind intended to establish or obtain favors or benefits. In this context, COGNE ACCIAI SPECIALI SPA considers only professional competence, reputation, independence, organizational skills, accuracy and timely execution of the contractual obligations and tasks assigned. COGNE ACCIAI SPECIALI SPA agrees to pay to consultants and staff bonuses based only on the provision specified in the contract. Payments cannot be made to a person other than the contractor or a third country other than that of the parties or the contract performance if not for reasons related to the contract or the office. 11. RULES OF CONDUCT IN RELATIONS WITH SUPPLIERS 4 Inclusive offers or promises of money or other benefits 5 Violence or threats Pagina 7 di 13

The relationship with suppliers is based on principles of transparency, fairness, integrity, confidentiality, diligence, professionalism and objectivity. In tenders, procurement and, generally, the supply of goods and/or services, is prohibited on the basis of publicly available information and/or available in compliance with the regulations, to establish and maintain relationships with: those involved in illegal activities and, anyway, with people lacking the necessary requirements of professionalism and commercial reliability; subjects that, even indirectly, hinder human development and contribute to not respect human dignity and the individual and/or violate the fundamental rights of the person; people who do not respect the law concerning employment, with particular attention to child labor, and health and safety of workers and in the general principles established by this. Recipients involved in procurement and supply processes ensure compliance with all relevant regulations. COGNE ACCIAI SPECIALI SPA recommends that its suppliers avoid to offer goods or services, in particular in the form of gifts, to employees of the company that exceed the normal standards of courtesy. It is forbidden to offer goods or services to employees of other companies or organizations in order to obtain confidential information or significant direct or indirect benefit for themselves or for the company. Procurement processes are based on the search for maximum competitive advantage for the Company granting equal opportunities for all suppliers, loyalty, fairness and competitiveness considerations. The choice of suppliers and the purchase of goods and services are carried out by specific company s functions and are based on objective evaluations of legality, competency, competitiveness, quality, honesty, respectability, reputation and price. It is absolutely forbidden to promise or pay sums of money or goods in kind to any person belonging to other companies to promote or further the interests of COGNE ACCIAI SPECIALI SPA. Suppliers of COGNE ACCIAI SPECIALI SPA should not be involved in illegal activities and should ensure that their employees working conditions are based on respect for fundamental human rights, international conventions and laws. In case of violation of the principles of legality, fairness, transparency, confidentiality and respect for the dignity of the person COGNE ACCIAI SPECIALI SPA it is entitled to take appropriate measures, up to the termination of the relationship with the supplier. 12. RULES OF CONDUCT IN RELATIONS WITH CUSTOMERS The professionalism, competence, willingness, respect and fairness are the guiding principles and way of conduct to be followed in dealing with customers. It is absolutely forbidden to promise or pay sums of money or goods in kind to anybody to illegitimately ease or facilitate, in any form, the interests of COGNE ACCIAI SPECIALI SPA. The activities COGNE ACCIAI SPECIALI SPA is constantly directed towards fulfilling the customers requests, with full respect for the law and the principles of transparency and competitiveness in trade relations. In particular, relations with customers are based on fairness and impartiality and respect for the law and independence against any form of conditioning, both internally and externally. Contracts and customer communications must: Pagina 8 di 13

be clear and understandable; comply with standards, without resorting to elusive or improper practices; comply with the company policies and definite trade parameters; complete and not overlooking any elements relevant to the customer's decision. In business relations with customers it is forbidden to hold any conduct that may harm consumer confidence and affect transparency and market security. 13. RULES OF CONDUCT RELATED TO CORPORATE, ADMINISTRATIVE OR FINANCIAL ACTIVITIES Recipients are required to have a correct, transparent and collaborative conduct, in compliance with the law and internal procedures, in all activities concerning preparation of financial statements and other corporate communications, in order to provide shareholders and the public a true and fair information on the economic and financial position of the Company. Every operation or transaction must be accurate, verifiable, legitimate. This means that each transaction and operation must be adequately accounted for and must be supported by appropriate documentation, in order to enable the performance of controls, the identification of different levels of responsibility and the accurate reconstruction of the operation. All those who for whatever reason, even as mere data providers, are involved in the preparation of financial statements and similar documents and/or of documents that represent the economic, equity or financial situation of the Company, and in particular to Directors, Statutory Auditors and Top Managers: must offer full cooperation and ensure the completeness and clarity of the information provided and the accuracy of the data and calculations; are forbidden to expose facts that are untrue, even when subject to evaluation, or omit information or conceal data in direct or indirect violation of regulatory principles and internal procedural rules, so as to mislead the recipients. It is absolutely forbidden to set up or maintain accounts or funds for a purpose that is not fully documented. It is forbidden to engage in sham transactions or spread false information about the Company and its activities. It is forbidden to prevent or in any way hinder control activities legally attributed to shareholders or other corporate bodies. It is forbidden to engage in simulated or fraudulent conduct aimed at influencing the Assembly in order to procure for themselves or others an unjust profit. COGNE ACCIAI SPECIALI SPA ensures widespread adoption and observance of conducts aiming at the preservation of capital and at the protection of creditors and third parties interests that establish relations with the company. In particular, it is expressly forbidden to: return capital to shareholders or to free them from the obligation to make contribution of share capital, apart from cases of legitimate reduction of share capital; distribute profits or advances on profits not actually realized or allocated by law to reserves or distribute restricted reserves; purchase or subscribe shares of the Company except in cases provided by law, damaging the integrity of the share capital; reduce the share capital, mergers or demergers, in violation of the provisions of law to safeguard the creditors, thus damaging their interests; Pagina 9 di 13

create or fictitiously increase share capital by allocating shares to a value lower than their nominal value at the increase of the share capital, reciprocal subscription of shares, overvaluation of contributions in kind or of credits or of the value of the Company in case of transformation; make any kind of illegal operation on shares of the Company (or its parent company); engage in any kind of operation that can cause damage to creditors; determine, with simulated or fraudulent acts, false majorities in the Assemblies of the Group Companies. 14. RULES OF CONDUCT FOR THE PROTECTION OF INDUSTRY AND COMMERCE COGNE ACCIAI SPECIALI SPA protects the value of fair competition by refraining from any collusive behaviors. The Company and its employees must comply with the principles and rules of free competition and must not violate the laws of competition, antitrust and consumer protection. It is forbidden to engage in any conduct that violates free trade at detrimental to commercial confidence and good faith in business. In respect of fair competition and consumer protection, COGNE ACCIAI SPECIALI SPA and its employees must not violate the rights of others related to intellectual property and to comply with the rules protecting the distinctive signs of creative works or products industrial (trademarks, patents, etc.). It is forbidden to market products that present the use of signs, figures or inscriptions bearing false indications sufficient to induce the consumer misunderstanding on the actual origin of the product. Specific controls are carried out on quality, provenance and origin of the raw materials / semi-finished products and on products subject to further commercialization, also through the inclusion of contractual clauses with suppliers and sub-suppliers, ensuring not to violate the rights of others. 15. RULES OF CONDUCT IN THE USE OF COMPANY ASSETS AND INFORMATION The assets of COGNE ACCIAI SPECIALI SPA are the resources with which the company conducts its business. Such assets include physical properties such as buildings, machinery and goods, as well as intangible assets such as confidential information, inventions, business plans and ideas, whether stored on paper, computer or knowledge of individuals. Each Recipient is responsible for protecting the company's assets under its direct control. Everyone must pay attention to safety procedures and oversee the situations that could lead to the loss, theft or misuse of company assets. Documents, working tools, plant and equipment and other assets, tangible and intangible (including trademarks and patents) owned by COGNE ACCIAI SPECIALI SPA must be used exclusively for the realization of business purposes, in the manner determined by the Company. Company s assets cannot be used for non-legitimate uses and should be used and kept with the same care of personal property. Illicit uses are punishable, also disciplinarily, whether or not constituting criminal behavior punishable by law. The company protects the personal data of individuals and entities according to relevant regulations. Pagina 10 di 13

COGNE ACCIAI SPECIALI, its employees and collaborators must treat data and information learned as required by the law and respecting the duty of confidentiality. These duties must be observed also after the termination of the relation with the company. The ICT and electronic tools (such as telephones and fax, email, internet, intranet and typically all hardware and software provided) that are made available to Recipients must be considered as working tools and must be used for business purposes only. Each Recipient is required to provide the necessary commitment to prevent the possible commission of crimes through the use of ICT tools. It is forbidden: the unauthorized access to a computer or telecommunications system; unauthorized storage and unlawful distribution of access codes to computer or electronic systems; the distribution of equipment, devices or programs intended to damage or interrupt a computer or telecommunications system; interception, impediment or interruption of communications or telecommunications; information, data, computer programs and computer and telematic systems damage. It is forbidden to upload on the company s systems software that is borrowed, unauthorized or lack of the necessary licenses. It is prohibited to make unauthorized copies of programs under license, for any use and purpose. 16. PROHIBITION OF OPERATIONS AIMED AT RECEIVING, LAUNDERING AND USE OF MONEY, GOODS OR UTILITIES OF ILLEGAL ORIGIN AND SELF MONEY LAUNDERING COGNE ACCIAI SPECIALI SPA conducts its business in compliance with the rules in force concerning antimoney laundering (AML) and of all provisions issued by the competent authorities. COGNE ACCIAI SPECIALI comply with the principle of maximum transparency in commercial transactions and use the most appropriate instruments in order to combat the phenomena of fencing, money laundering and use of money, goods or assets of illicit origin. Recipients should never be engaged or involved in any activity which may imply money laundering, ie the acceptance or processing of proceeds of criminal activities in any form or manner. Recipients, before establishing business relations with counterparts, consultants and suppliers, must check, according to the available information (including financial information), their integrity, their respectability and the legitimacy of their activities. Recipients are required to adhere strictly to the laws, policies and procedures in any economic transaction (including intra-group) that sees them involved, ensuring full traceability of cash inflows and outflows and the full compliance with the laws of AML where applicable. Recipients must not perform operations that involve money self-laundering, such as the use, exchange or transfer of activities in other economic, financial, entrepreneurial or speculative activities when those are from illegal acts connected also to tax legislation. 17. RELATIONS WITH THE COMMUNITY 17.1. Trade Unions and Political Parties COGNE ACCIAI SPECIALI SPA does not make contributions of any kind, directly or indirectly, to political parties, movements, committees and political and trade union organizations and their representatives and candidates, except in the form and manner determined and/or required by law. Pagina 11 di 13

17.2. Press and Mass Media COGNE ACCIAI SPECIALI SPA maintains relationships with the press and mass media only through Top Managers/Directors and/or specifically appointed functions. Relations must be based on principles of fairness, willingness and transparency in respect of the communication policy defined by the Company. Information and communications relating to the Company must be accurate, complete, accurate, transparent and consistent. It is forbidden to provide information to the media mass without prior and specific authorization of the competent Function. 18. OBSERVANCE OF THE CODE OF ETHICS Violation of the provisions of this Code damages the relationship of trust established with the Company and may lead to disciplinary action and compensation for damage. The observance of the Code by employees and collaborators and their commitment to respect the general duties of loyalty, honesty and compliance with the employment contract in good faith should be considered an essential part of the contractual obligations. COGNE ACCIAI SPECIALI SPA is consistently involved to ensure the adequate knowledge of the Code of Ethics, spreading it through the Recipients with appropriate information and communication activities. COGNE ACCIAI SPECIALI SPA has constituted a Supervisory Body with independent powers of initiative and control. The Supervisory Body has been entrusted with the task of supervising the functioning and compliance to the Organizational Model pursuant to Italian Legislative Decree no. 231/2001, as well as to provide its continuous updating. The Supervisory Body has also the task of promoting the knowledge and awareness of the and to look after its implementation and updating. To this end, the Supervisory Body must take action, through the relevant corporate functions, to prevent or to punish breaches of the All those in need of clarification on the principles and provisions of the should contact the Supervisory Body. Any violation of the by the Recipients must be reported promptly to the Supervisory Body - odv@cogne.com. Each report groundlessly presented is a violation of the. The Supervisory Body will then make the relevant inquiries, also through the relevant department and, if necessary, inform the competent company s functions for the imposition of disciplinary measures. In case of violation of the by Directors of COGNE ACCIAI SPECIALI SPA, the Supervisory Body will inform the Board of Directors and the Statutory Auditors of the Company which will then take the appropriate steps in accordance with the current legislation which, if the case, includes the shareholders' meeting and the proposal of the revocation and/or of the action and responsibility. Any behavior of employees, in violation of rules of conduct or procedures contained in this, will be considered disciplinary offense and then punishable in accordance with the applicable regulations. Detection of violations, management of disciplinary proceedings and the imposition of sanctions are responsibility of the Human Resources department. Compliance with the by third parties (suppliers, consultants, etc.) integrates the obligation to fulfill the duties of care and good faith in negotiations and execution of contracts with the Company. Pagina 12 di 13

Violations committed by third parties will be dealt with in accordance with provisions in the relevant contracts. 19. MODIFICATION OF THE CODE OF ETHICS The Company is committed to update the content of the if necessitated by the change of context, the relevant legislation, the environment or the corporate organization. The Board of Directors is responsible for any changes and / or additions to this. The Italian language has been used in preparing the original of this document and in case of disagreement between the translation and the original Italian version of this document, the original Italian version will prevail. Pagina 13 di 13