MODEL 231

CIPRIANI MILANO, sensitive to the need to spread and consolidate the culture of transparency and integrity, as well as aware of the importance of ensuring conditions of correctness and transparency in the conduct of business and corporate activities, to protect its position and image, the expectations of its shareholders and the work of its employees, has deemed to be compliant with its Company policy to proceed with the adoption of the Organization and Management Model envisaged by
Legislative Decree 231/2001 ("Model 231").

Model 231 itself, as an optional and non-mandatory element, also aims to raise awareness of all those who operate in the name and on behalf of the Company, so that they follow, in carrying out their activities, correct behavior in line with Company procedures, such as to prevent the risk of committing the crimes contemplated in the Decree itself.