Ethics

The principles and values that guide our daily actions and define our corporate identity, in full compliance with Italian Legislative Decree 231/2001.

Introduction

San Giorgio Servizi S.r.l., in compliance with the regulations on the prevention of offences provided for by Italian Legislative Decree 231/2001 and subsequent amendments, has drawn up this Code of Ethics as a tool to prevent such offences and to protect the company’s image and reputation. The Code of Ethics is an integral part of the Organisation, Management and Control Model adopted by the Company pursuant to Legislative Decree 231/2001.

Purpose

The San Giorgio Servizi Code of Ethics aims to clearly define the values, principles and ethical responsibilities that must guide the behaviour of all those who operate within the organisation or in its name and on its behalf.

This document:

• Sets out ethical and conduct standards that must be observed by directors, employees, contractors and partners
• Prevents unlawful behaviour and conduct contrary to company values
• Protects the image, reputation and integrity of the company
• Constitutes an integral part of the Organisation, Management and Control Model pursuant to Legislative Decree 231/2001

Scope of application

This Code of Ethics applies to:

• Directors and members of corporate bodies of the company
• Employees at all levels
• External collaborators, consultants and professionals who operate in the name and on behalf of the company
• Business partners, suppliers and third parties who maintain ongoing relations with San Giorgio Servizi

All recipients of the Code are required to know its contents and to comply strictly with its provisions.

Corporate mission

San Giorgio Servizi operates with the objective of providing excellent services in the area of credit recovery, in full respect of the law, ethical principles and human dignity. Our mission is to support clients in the professional and transparent management of credit recovery, ensuring:

• Professionalism and specialist expertise
• Protection of debtors’ dignity
• Transparency in procedures and business relationships
• Compliance with applicable legislation
• Continuous innovation in processes and operational tools

General principles

Conduct guidelines

Personnel management

San Giorgio Servizi regards its personnel as a fundamental resource. The company undertakes to:

• Recruitment: ensure transparent selection processes based on merit, skills and professional qualifications, avoiding any form of discrimination
• Training: promote professional growth through continuous training, with particular attention to the legal and ethical aspects of the activities carried out
• Health and Safety at work: ensure a safe and healthy working environment, in compliance with health and safety regulations (Italian Legislative Decree 81/2008)
• Dignity and respect: prevent any form of harassment, bullying, discrimination or abuse, fostering a climate of mutual respect
• Conflicts of interest: avoid situations in which personal interests may conflict with company interests

Relations with clients

In relations with clients, San Giorgio Servizi undertakes to:

• Provide quality services with professionalism, expertise and timeliness
• Ensure complete, truthful and transparent information on the services offered
• Respect the confidentiality of information acquired
• Avoid any form of conflict of interest
• Refuse assignments that may entail violations of the law or of this Code
• Respect contractual agreements and commitments undertaken

Relations with suppliers

The selection and management of relations with suppliers must be based on transparency, fairness and fair competition. In particular:

• Suppliers are selected on the basis of objective criteria such as quality, price, reliability and compliance with ethical standards
• It is forbidden to request or accept gifts, favours or benefits of any kind that may compromise the impartiality of decisions
• Contracts with suppliers must be in written form and comply with applicable regulations
• Suppliers are required to know and comply with this Code of Ethics

Relations with Public Authorities

In relations with Public Administrations, supervisory authorities and public institutions, San Giorgio Servizi acts in compliance with laws and regulations. It is strictly forbidden to:

• Promise, offer or grant, directly or indirectly, money, gifts, advantages or benefits of any kind to public officials or persons in charge of a public service
• Exert undue pressure on public officials in order to obtain preferential treatment
• Submit false or altered statements or documents
• Omit required information
• Maintain relations that are not in line with internal authorisation procedures

Administrative and accounting transparency

Correct and transparent accounting is a fundamental principle. Every operation and transaction must be:

• Authorised, verifiable, legitimate, consistent and appropriate
• Recorded correctly and promptly in the accounts
• Supported by adequate documentation allowing verification
• Easily reconstructable through appropriate traceability

It is forbidden to:

• Record non-existent or false transactions
• Omit the recording of transactions carried out
• Create hidden funds or reserves
• Alter or falsify accounting documents

Protection of intellectual property

San Giorgio Servizi respects third-party intellectual property rights and is committed to protecting its own. It is forbidden to:

• Use software or content without the necessary licences
• Disclose confidential information or company know-how
• Infringe third-party patents, trademarks or copyrights

Protection of personal data

San Giorgio Servizi guarantees compliance with regulations on the protection of personal data (GDPR – EU Regulation 2016/679 and Italian Legislative Decree 196/2003). The company processes personal data of clients, employees, collaborators and third parties lawfully, fairly and transparently, adopting appropriate technical and organisational measures to ensure their security.

Environmental protection

San Giorgio Servizi recognises the importance of environmental protection and is committed to:

• Complying with all applicable environmental regulations
• Promoting responsible and sustainable use of resources
• Minimising the environmental impact of its activities
• Encouraging sustainable practices and reducing waste

Implementation and supervision

This Code of Ethics applies to all employees, collaborators, consultants, directors and partners of San Giorgio Servizi. Compliance with the Code is considered an essential part of contractual obligations.

Breaches of the principles set out in the Code may result in:

• Disciplinary measures against employees, in accordance with collective agreements and applicable legislation
• Termination of contractual relationships with collaborators, consultants and suppliers
• Administrative liability of the company pursuant to Legislative Decree 231/2001, in the event of relevant violations

Supervisory Body (Organismo di Vigilanza – OdV): a Supervisory Body has been established in accordance with Legislative Decree 231/2001, with the task of:

• Monitoring compliance with and effective implementation of the Code of Ethics and the Organisation Model
• Periodically verifying the adequacy of the Code of Ethics in relation to the company’s activities
• Receiving and assessing reports of alleged violations
• Proposing updates and amendments to the Code of Ethics
• Promoting training and awareness programmes

Dissemination and updating

This Code of Ethics is:

• Made known to all recipients through publication on the corporate website and direct delivery
• Subject to periodic training for all employees and collaborators
• Made available to stakeholders and interested parties

San Giorgio Servizi reserves the right to update this Code of Ethics in line with regulatory developments, organisational changes and sector best practices. Any changes will be promptly communicated to all recipients.

Code of Ethics – Version 3.0
Last update: October 2025