INFORMATION RELATING TO THE LEGISLATIVE DECREE. N. 196/2003 ON PRIVACY PROTECTION AND REQUEST FOR CONSENT TO DATA PROCESSING

In compliance with current legislation, we inform you that pursuant to the Legislative Decree 30 June 2003 n. 196 (and subsequent modifications) the data you provide will be processed, always, having regard to the obligations and in compliance with the regulations indicated above. According to the article 4, comma 1, letter A, of the Legislative Decree 30 June 2003 n. 196 (commonly referred to as the “Privacy Code”) treatment must be understood: “any operation or set of operations, carried out with or without the aid of electronic or automated means, concerning the collection, the registration, the organization, conservation, the processing, the modification, the selection, extraction, the comparison, use, the interconnection, the block, the comunication, the diffusion, the deletion and destruction of data”.

Purpose of the processing Pursuant to the Legislative Decree 30 October 2003 n. 196, We inform you that by completing and sending this form you will accept the following: 1.provide members who have entered their email address with training and/or information material (newsletters); The sending of training and/or informational material (newsletters) will be sent free of charge to the email address indicated..

Data processing methods The data will be processed using suitable tools to guarantee security and confidentiality, with and without the aid of automated means capable of memorizing, manage and transmit the data themselves. At any time you can revoke the consent given and/or oppose the processing of your data.

Rights of the interested party In accordance with the provisions of the article 7 e 8 of the Legislative Decree 30 June 2003 n. 196, We inform you that you are entitled: 1.to know the existence of personal data concerning you, which must be made available to you in an intelligible form; 2.to know the origin of the data concerning you; 3.to know the purposes and methods of the processing; 4.to know the logic applied in case of processing carried out with electronic instruments; 5.to know the details of the owner and those responsible for the processing; 6.to know the subjects or categories of subjects to whom the personal data may be communicated; 7.to the update, rectification or integration of personal data concerning you; 8.upon cancellation, to the transformation into anonymous form or blocking of personal data concerning you, whose processing had not been correctly authorised; 9.to oppose for legitimate reasons the processing of data even if pertinent to the purpose of the collection; 10.to oppose the processing of data provided for the purpose of sending advertising material or for the purposes of commercial information.

ORGANIZATION, MANAGEMENT AND CONTROL MODEL pursuant to Legislative Decree. 231/2001

By resolution of the Shareholders' Meeting of 09/03/2009 the company AdIM Srl (My name ) has adopted the Organization Model, management and control, provided for by the Legislative Decree. Lgs. n. 231/2001. At the same meeting, the Company's Code of Ethics was also approved and the Supervisory Body was established, according to the article 6, 1° comma,letter b) of D. Lgs. n. 231/2001. Since the art. 6, comma 1, letter a) del D.Lgs. 231/2001, provides that the Model is an "act issued by the management body" its subsequent substantial modifications and additions are left to the competence of the Shareholders' Meeting. Although the adoption of the Model is provided for by law as optional and not mandatory, AdIM decided to proceed in this direction, for the purpose of protecting society, to guarantee its employees, to clearly demonstrate to third parties the commitment to following the principles of conduct better illustrated in the Code of Ethics.

The code of ethics

STEP srl, (My name) in carrying out its business activities, refers to ethical principles that can be derived from a wealth of individual and corporate values. Such values, which must be the basis of the conduct of all those who, at various levels of responsibility, contribute with their actions to the carrying out of the overall activity of the company, and I'm: Value creation: continuously improve financial strength and ability to generate profit, guaranteeing the company autonomy and continued success. Ethics and transparency : commitment to respecting one's values ​​and founding relationships with partners and customers on the basis of mutual respect. Professionalism: deep commitment to improving customer services by maintaining relationships of trust and fairness. Team spirit: be creative and innovative, developing synergies and strengthening solidarity. The Code of Ethics is the corporate document that indicates: a. the set of principles, of values, of the lines of conduct that Administrators must follow, collaborators within the scope of their functions and work activities as well as all those who directly or indirectly, operate permanently or temporarily, even in a professional capacity, with AdIM; b. the organizational system set up by AdIM for the constant monitoring of the effective application of the aforementioned principles, values ​​and lines of conduct; c. the disciplinary system and sanctioning mechanisms set up by ADIM in case of violation of the aforementioned principles, values ​​and lines of conduct. ADIM has identified the Code of Ethics as an essential and essential tool to achieve its mission. The Code of Ethics (CE) it also constitutes a fundamental element of the set of internal rules and procedures adopted by AdIM for the implementation of the regulations provided for by the legislative decree 8 June 2001, n. 231 e s. m.i. on the subject of administrative responsibility of companies. This CE is also consistent with the "Guidelines for the construction of Organization Models,Management and Control pursuant to Legislative Decree. n. 231/2001” of the Confapi trade association. The Code of Ethics applies to all those who work at the company, both as employees and as subjects who in any capacity provide their contribution in carrying out AdIM's business activities . All employees have the right and obligation to know it, apply it, request explanations if in doubt, report any gaps found or the need to proceed with its updating and adaptation. In particular, the Management of AdIM srl is required to apply the CE and implement the necessary information activities for its collaborators. In particular, are recipients of this CE: a. AdIM Members b. AdIM personnel such as employees, c. the consultants, the collaborators, agents and suppliers of goods and services (even professional ones) and all those who carry out activities in the name and on behalf of AdIM d. third parties who do not carry out activities in the name and on behalf of AdIM such as, for example, customers. The CE is shared: a. by delivery to members, to employee staff, to collaborators and external consultants, the CE is posted on the company noticeboard. b. it is reported in the brochure and is published on the website www.adimnews.info Lines of conduct Fair and fair competition AdIM operates in a competitive context and considers fair and fair competition an essential principle that must characterize all actions and in general all behavior of directors, employees as part of their work activity as well as all those who directly or indirectly, operate permanently or temporarily, also in a professional capacity with AdIM . Legitimacy and correctness of behavior All actions and in general all behavior of directors, members and employees within the scope of their functions and work activities as well as all those who directly or indirectly, operate permanently or temporarily, even in a professional capacity with AdIM they must be characterized by maximum legitimacy, correctness, transparency and truthfulness. All company activities must be carried out with the utmost diligence, honesty, loyalty and professional rigor. Prohibition of any discrimination and development of human resources AdIM avoids any form of discrimination, starting from the staff selection and recruitment phase, and actively promotes policies aimed at rewarding individual merit in a context that ensures equal opportunities and maximum respect for human dignity. It promotes the physical and psychological integrity of its employees and all those who find themselves working in any capacity with AdIM, constantly promoting and ensuring the creation of a working environment that guarantees safety, respect for privacy and individual beliefs as well as individual relationships inspired by maximum fairness. AdIM actively collaborates with institutional bodies, offering them all the possible collaboration with the utmost loyalty and correctness.