Betty Blue recognises the importance of ethical and social values in work and business. Consequently, it is committed to sound and responsible management of its own activities and those of its social partners, with respect for the community of which it is a part.

This commitment gave rise to this Code of Ethics, which has the following aims:

Define the fundamental ethical principles of Betty Blue;
Establish rules of conduct for those who work with it and for it;
Foster dialogue, involvement and consensus;
Indicate the basis for a voluntary agreement to ethically regulate relations between Betty Blue and its stakeholders;
Represent the basic element for the adoption of the Organisational Model pursuant to Legislative Decree 231/2001 on the administrative liability of entities.

The following behaviours are considered unethical by Betty Blue:

Appropriating the benefits or cooperation of others through positions of power or strength;
Non-compliance with applicable laws, regulations and standards;
Altering the accuracy and truthfulness of the data contained in the financial statements;
Obstructing the control functions of public authorities.

The rules of conduct, values and principles set out below, as part of Betty Blue's system of governance, enshrine the Company's commitment to limit its freedom to operate in purely opportunistic terms and to ensure that all stakeholders participate and engage in dialogue.

Betty Blue's system of governance guarantees effective management of the company's activities and a system of internal and external controls suitable for covering operational risks.

In the pursuit of its corporate mission, Betty Blue shall ensure that the principles of this Code are received and shared by its management, its employees (hereinafter also referred to as consultants, partners and non- members), its customers and suppliers and civil society.

This Code of Ethics consists of:

Values and principles of a general nature, which the Code is inspired by and which Betty Blue intends to protect and share with its stakeholders;
Rules of conduct of a particular nature, to be followed by Addressees of the Code;
Rules for implementing the Code and monitoring compliance with it.

The document is approved by the Board of Directors, which will circulate it to all interested parties.

The Company's commitment is to ensure that the activities of its services are carried out in compliance with the law, with honesty, integrity and fairness and in good faith, respecting the legitimate interests of users, employees, collaborators and contractual partners.

1. Recipients

Addressees of the Code of Ethics are:

The members of the corporate bodies (president, directors, board members and auditors);
Employees and other persons, including through consultancy contracts;
The Company's other collaborators and suppliers who, directly or indirectly, permanently or temporarily, establish relations or connections with Betty Blue within which they work to pursue its objectives.

In view of this, Betty Blue is committed to the dissemination of this Code to all stakeholders, to the correct interpretation of its contents and to the provision of tools to facilitate its application.

Betty Blue trusts addressees to behave in accordance with the values and principles of the Civil Code, bringing it to the attention of customers, suppliers and the Company.

Betty Blue also implements the necessary measures to carry out verification and monitoring activities of the application of the Code itself, providing for sanctions in the event of its violation.

For this purpose, a special internal body is responsible for supervising the application of the Code, among other tasks.

2. Values and Principles

a. General Principles

Betty Blue refers to the great values of civilisation and democracy enshrined in the Constitutions of the Italian Republic and the European Union and in the United Nations Universal Declaration of Human Rights, recognising dignity, freedom, equality, solidarity and justice as the essential values of civilised living. In particular, it is fully recognised in Article 41 of the Italian Constitution, according to which private economic initiative 'may not be carried out in conflict with social utility or in such a way as to damage security, freedom and human dignity'.
Betty Blue orients its activities to the principles contained in this Code, declaring itself free not to enter into or continue any relationship with those who demonstrate that they do not share its content and spirit and/or violate its principles and rules of conduct.

b. Transparency and completeness of information and communications

Betty Blue is committed to informing relevant social stakeholders clearly and transparently about its situation and performance, without favouring any stakeholder or individual.
Financial, accounting and management records and any other communications meet the requirements of truthfulness, completeness and accuracy.
Betty Blue recognises the fundamental value of providing correct information to shareholders, competent bodies and functions regarding significant facts concerning corporate and accounting management.

c. Respect for legality

Betty Blue takes strict compliance with all applicable regulations as an unwavering principle.
Betty Blue adopts internal procedures and models of organisation and control aimed at preventing and opposing any conduct contrary to the principle of legality and promotes a "culture of internal control" among all addressees.
Betty Blue makes every effort, within its competence, to fight corruption, terrorism, money laundering and all other forms of crime.
Betty Blue intends to pursue its own interest through honest conduct and in compliance with the law at all times.
Betty Blue undertakes to adopt useful and appropriate measures to ensure that this constraint of respect and ethical conduct is adopted and practised by shareholders, directors, executives, employees and collaborators in general, as well as by consultants, suppliers, customers and any subject with whom it has relations.
Each addressee is responsible, to the extent of their competence, for the internal control system and the compliance of their activities with the principles of the Code; in particular, each employee, within the scope of their role and competence, is responsible for the proper functioning of the internal control system.

d. Correct corporate management and use of resources

Betty Blue pursues its corporate purpose in compliance with the law and the Articles of Association, ensuring the proper functioning of the corporate bodies and the protection of the patrimonial and participatory rights of the shareholders, safeguarding the integrity of the share capital and assets. The use of Betty Blue's resources is marked by the utmost transparency, with periodic reporting to the competent internal and external control bodies.

e. Relations with Public Administrations

All those working in the name and/or on behalf of Betty Blue must conduct themselves in such a way as not to induce the Public Administration to violate its principles of good administration and impartiality.
The persons appointed by Betty Blue to follow negotiations and/or relations with the Public Administration may not for any reason engage in conduct aimed at illegitimately influencing the Public Administration's decisions in order to obtain an illicit or undue advantage or interest for Betty Blue.
Betty Blue prohibits and condemns any behaviour, carried out by those who work in its name and on its behalf, consisting of promising or offering, directly or indirectly, money or other benefits to Public Officials and/or Public Service Managers in order to obtain an illicit or undue advantage or interest for Betty Blue.
Betty Blue prohibits and condemns any conduct, carried out by those working in its name and on its behalf, aimed at obtaining contributions, financing or other proceeds from the Public Administration, by means of forged or altered declarations and/or documents or omitted information, or more generally as a result of artifice or deception intended to mislead the awarding Body.
Contributions, subsidies or financing obtained from the Public Administration, even if of small value, may not be allocated to purposes other than those for which they were granted.

f. Protecting and empowering people and business democracy

Betty Blue recognises the centrality of human resources and the importance of establishing and maintaining relations with them based on loyalty and mutual trust. In this sense, human resources are primarily understood as all those who work for Betty Blue, even under contracts other than direct employment.
All human resources undertake to act loyally in order to comply with the obligations arising from the employment contract and the provisions of the Code of Ethics, guaranteeing the services they are asked to provide and respecting the commitments they have undertaken.
This commitment shall be upheld even in the event that such persons become aware of conduct contrary to that defined herein, which has been committed by other recipients of the Code.
The management of the employment relationship is based on respect for the individual, fairness and respect for equal opportunities, without any discrimination based on gender, race, religious belief, political opinion, age or state of health.
All staff are employed under regular employment contracts; no clandestine or otherwise irregular employment is allowed.
The decision to enter into an employment relationship or to entrust a collaboration mandate must be made on the basis of candidates' profiles and specific skills meeting the company's needs, while respecting the equal opportunities of the candidates.
The information requested must be strictly related to the verification of the professional and psycho-aptitude requirements, while respecting the candidates' privacy and their political and social views. At the time the collaboration begins, the person receives comprehensive information about the characteristics of the job and role, regulatory and salary elements and regulations and behaviour for managing personal health risks.
Any form of discrimination against persons is prohibited.
All decisions taken in the area of human resources management and development are based on considerations of merit and/or people's profiles corresponding to those desired. The same applies to access to different roles or positions.
Budget objectives, both general and individual, for employees or collaborators, must be objectively achievable, in relation to the time available to achieve them and the means available.
Betty Blue promotes the growth of professionalism through training activities and the sharing of knowledge, due to its belief that individual and collective contributions to work processes represent an indispensable element for everybody's development and personal growth.
In the management of hierarchical relations, authority is exercised fairly and appropriately, avoiding any abuse. Requesting, as a due act from the hierarchical superior, any services, personal favours or any behaviour that constitutes a violation of the Code of Ethics constitutes the abuse of a position of authority.
In the case of company and/or production reorganisations, the value of human resources is safeguarded by providing, if necessary, training and/or retraining actions.
Betty Blue recognises and respects the role of trade unions and their full right to exercise their activity of representing workers. It promotes the dissemination of a correct system of industrial relations, including by strengthening the participation of workers and trade unions in the development of the company.
Betty Blue supports and respects human rights, in accordance with the UN Universal Declaration of Human Rights.

g. Health and safety

Respect for people's physical and cultural integrity represents an ethical foundation for Betty Blue. Betty Blue strives to ensure health and safety in the workplace and exercise the utmost fairness in the management of employment relations, in compliance with contracts and the applicable laws in force.
Betty Blue systematically complies with all measures required by current legislation on health and safety in the workplace.
Betty Blue informs, boosts and raises awareness among all staff to ensure carelessness or neglect does not thwart the organisational efforts in place.
Personnel and all company employees in various capacities must scrupulously observe the instructions given in relation to safety.
Betty Blue puts in place methodologies to systematically control and monitor the correct adoption of all required safety measures.

h. Social and environmental responsibility

Convinced that it is possible to combine the need for profitability with respect for ethical values and the protection of environment, Betty Blue pursues the objective of fostering not only the economic, but also the cultural and moral development of the community. It invests in renewable energies and takes care of the environmental impact of its activities, paying attention to waste disposal, the consumption of energy resources and the emissions produced.
The company operates in strict compliance with national and local environmental legislation.
All those who make any purchase of goods and/or services must act in accordance with the principles of fairness, cost-effectiveness and quality and operate with the diligence of a good guardian, verifying the suppliers' compliance with the principles of the Code of Ethics, with particular regard for the protection of workers' rights and respect for the environment.

i. Animal protection

In line with the commitment of its owners, the company cultivates a passion for animals and the strenuous defence of their rights, in the name of cruelty-free fashion. Angora, real down and fur are banned in Elisabetta Franchi's collections.
The company promoted the first Dog Hospitality project in Italy, which allows company employees to bring their four-legged friends into the office with them.

j. Safeguarding the corporate image

Betty Blue's reputation is an intangible asset of absolute value that enables it to develop trusting relationships with its stakeholders.
Betty Blue trusts all addressees to represent it professionally, honestly, seriously and fairly and to work to protect its image.

k. Fair competition and fair advertising

Betty Blue promotes the culture of fair competition in the markets in which it operates and acts in compliance with the anti-monopoly regulations in force, both national and European, in its relations with customers, suppliers and competitors. The Company's advertising communications are transparent, correct, accurate and appropriate, and do not mislead the persons to whom they are addressed nor harm a competitor.
Betty Blue, through the persons acting on its behalf, does not offer or accept money or goods in any form whatsoever to promote or favour the conclusion of business for its own benefit in violation of laws, regulations in force or fair competition. Courtesy gifts are permitted when they are of modest value and are not appreciable as a means of seeking favours or privileges, in violation of the laws in force or fair competition.

l. Protection and confidentiality of personal data and information

The processing of personal data relating to customers, employees, collaborators and suppliers is carried out with the utmost respect for the dignity of the data subject and their right to confidentiality and protection of personal data. Betty Blue undertakes to process such data in a lawful and fair manner, collecting only data that is pertinent and not excessive for the purposes for which it is collected.

m. Transparency in dealings with Supervisory and Control Authorities

Betty Blue's relations with the Supervisory and Control Authorities are marked by criteria of maximum collaboration and transparency. The protection of information transparency is fostered by compliance with the provisions in force and the internal procedures adopted on the matter.
It is forbidden to place any obstacle whatsoever in the way of the activities of the Supervisory and Control Authorities.

n. Associations and politics

Betty Blue's actions are governed solely by the principles of its Articles of Association and Bylaws, within a framework of respect for all opinions.
Betty Blue may contribute to the financing of associations and to the support of political parties and/or their information bodies, committees, organisations or political candidates, in accordance with the Articles of Association and the regulations in force.
Betty Blue may enter into normal commercial or legal relations with the same parties in compliance with the laws and regulations in force and this Code of Ethics.

o. Conflict of interest

Addressees of the Code shall refrain from performing acts in which they have, even indirectly, interests potentially in conflict with those of Betty Blue, such as, for example, personal or family interests of a financial or commercial nature with customers, suppliers or competitors.
It constitutes a conflict of interest if a director, manager, employee or collaborator pursues or attempts to pursue, for themselves or for third parties, an objective other than the objective pursued by Betty Blue, or voluntarily procures or attempts to procure for themselves a personal advantage in the performance of activities carried out in the interest of Betty Blue, or procures or attempts to procure the same for third parties.
Therefore, corrupt practices, illegitimate favours, collusive behaviour or the solicitation, directly and/or through third parties of personal and career advantages for oneself or others and other similar behaviour are prohibited.
Betty Blue's management, employees and collaborators refrain from giving and/or receiving gifts of any kind, except of symbolic value and in accordance with customary business practices, paying particular attention to relations with employees of the Public Administration.
Betty Blue's customers and suppliers are asked to refrain from giving gifts that may induce the Code's addressees to behave in a way that is contrary to the interests, including moral interests, of the Company.
Betty Blue recognises and respects the right of its employees and collaborators to participate in investments, business or other activities outside those carried out in the interests of Betty Blue, provided that these activities are permitted by law and by contractual and statutory provisions and are compatible with the obligations undertaken as partners, employees or collaborators.
Any situation that may constitute or determine a conflict of interest, even if potential, must be promptly communicated to the Supervisory Board and to the hierarchical superior. In particular, all partners, employees and collaborators of Betty Blue are required to avoid conflicts of interest between personal and family economic activities and the duties they hold within the structure they belong to, if not adequately made known and transparent through communication to the Supervisory Board.

Conflicts of interest may include, but are not limited to, the following situations:

Holding senior management positions (managing director, director, department head) and having significant economic or financial interests in suppliers, customers, competitors or business partners of Betty Blue, including through family members;
Using one's position in Betty Blue or information acquired in one's work in a way that may create a conflict between one's personal interests and the interests of Betty Blue;
Carrying out work of any kind with customers, suppliers or competitors;
Accepting or offering money, favours or benefits from/to persons or companies that have, or intend to enter into, business relations with Betty Blue. In the event of a conflict of interest, the person involved shall abstain from decisions that, although within their competence as a delegate or member of a collegiate body, result in the company choosing to enter into such a conflict-of-interest relationship.

p. Use of IT means

Betty Blue prohibits any practice that may violate the confidentiality of the computer systems of third parties, public or private, or otherwise cause damage to them, or is intended to falsify a public or private computer document with evidentiary effect.
Betty Blue requires compliance with the legislation in force concerning the processing of personal data and prohibits any practice that may violate the integrity and confidentiality of its own and third parties' data and computer systems.
It is also forbidden to use any unlicensed software in violation of copyright law.

3. Rules of conduct

Betty Blue recommends that the Code's addressees behave responsibly, in accordance with the achievement of the company's objectives and consistent with the values and principles set out.

Every operation and/or transaction must be legitimate, documented, recorded and verifiable at any time.

Betty Blue condemns any conduct by anybody which is aimed at altering the accuracy and veracity of the data and information contained in the financial statements, reports or corporate communications required by law.

Addressees are obliged to behave correctly and transparently in the performance of their duties, in particular with regard to any request made by Shareholders, Auditors or Public Authorities in charge of checks and/or controls, maintaining an attitude of helpfulness and maximum cooperation.

It is forbidden to intentionally spread false information, both internally and externally, about Betty Blue, its employees and collaborators.

In particular, addressees who, by virtue of the positions they hold or the duties they perform, have access to news or confidential information relating to the Company:

Must not disclose such news or information to third parties or use it for purposes outside their office;
Shall refrain from carrying out, directly or indirectly, on their own behalf or on behalf of third parties, transactions on the financial instruments of the Company using the same news or information.

a. Corporate bodies

The authority, professionalism, diligence and independence of judgement of Betty Blue's Chairman, Directors and Auditors guarantee the achievement of the company's goals and the protection of stakeholders' interests.
The administrative body promotes the culture of legality and monitors the full compliance of the company's activities with the law, regulations and company procedures. It also promotes the culture of internal control and ensures that those in charge of control have the utmost independence and autonomy of action.
The executive directors exercise their functions in compliance with the contents and limits of the delegated powers granted by the board of directors, to which they report on their actions.
It is forbidden to engage in any conduct on the part of the Company's Directors aimed at causing damage to the integrity of the Company's assets.
The directors must not engage in any type of corporate transaction that could cause damage to creditors.
Regarding conflict of interest, the activities of the directors comply with regulatory provisions and the relevant internal guidelines: any conflict situations are managed with total transparency and in such a way as to safeguard Betty Blue's interests.
Any other conduct that violates the relevant legislation on corporate offences is prohibited.

b. Human resources and the rights of the individual

Human resources are an indispensable factor for the existence, development and success of a company. For this reason, our Company protects and promotes the value of human resources in order to improve and increase the wealth and competitiveness of the skills possessed by each employee and internal collaborator in the corporate organisational context.
In this context, the contents of the 'Declaration on Fundamental Principles and Rights at Work' adopted by the ILO International Conference in 1998 and the fundamental conventions to which it refers are of strong relevance and reference, particularly in the areas of:
(a) Prohibition of forced labour: forced, slave or prison labour is prohibited;
(b) Freedom of trade union association and the right to collective bargaining: the right of workers and employers to organise and the right to form and/or join a trade union of their choice are recognised. Workers and employers can participate in collective bargaining freely and independently of public authorities;
(c) Prohibition of child labour and exploitative child labour: child labour is prohibited. The minimum age for admission to work must not be lower than the compulsory school completion age in force in the countries concerned;
(d) Prohibition of discrimination in employment: workers must be employed on the basis of their ability to work and without discrimination based on race, sex, individual characteristics, religious beliefs, political opinions or national or social origin;
(e) Prohibition of harassment: any behaviour, by any person, relating to sexual harassment or bullying, psychological violence, mobbing or straining1 against employees and collaborators is prohibited.
Betty Blue employees perform their duties with commitment, a sense of responsibility, loyalty and integrity, in compliance with legal and contractual provisions and company directives.
Each corporate position is responsible for the accuracy and originality of the documentation and information rendered in the performance of the activity for which it is responsible.
Each employee complies with the specific company provisions on conflict of interest and informs their hierarchical superior of transactions in which they have an interest, even indirectly, potentially conflicting with those of the company.
They are responsible for the preservation and protection of the assets and tools that Betty Blue places at their disposal for the proper performance of their work, avoiding improper use of the same for purposes unrelated to the activity.
With regard to Betty Blue's property, each employee or collaborator is obliged in particular to:

Avoid improper use that may cause undue cost, damage or reduction in efficiency or is otherwise contrary to the interests of Betty Blue;
Scrupulously follow the procedures in order not to compromise the functionality, protection and security of Betty Blue's computer systems, equipment and facilities;
Always operate in compliance with the safety rules laid down by law and internal procedures in order to prevent possible damage to property, persons or the environment;
Use such assets, of whatever type and value, in compliance with the law and internal regulations;
Use such assets exclusively for purposes related and instrumental to the exercise of business activity;
Avoid, except when specifically authorised, the use or transfer of the goods themselves by or to third parties, even temporarily;
Work to reduce the risk of theft, damage or other threats to these assets, informing the relevant positions in a timely manner in the event of abnormal situations.

'Data processors' keep and protect personal data in an appropriate manner, following the company regulations issued in this regard.
Everyone is required to strictly respect the confidentiality of data and information learned in the course of their work.
Betty Blue trusts that those performing coordination activities will behave with courtesy and respect towards their co-workers and promote their professional development.
1 Lo straining consiste in azioni ostili che producono duraturi effetti nei confronti di una persona che si trovi in posizione di inferiorità.

c. Employment of workers

Non-EU workers without a valid residence permit may not be employed by Betty Blue either directly in its own business or indirectly through external companies with which the Company has concluded a contract, of any kind, of employment, contracting or supply.

d. Collaborators

Betty Blue values the importance of the contribution of collaborators and consultants to the Company's daily business and asks them to operate with honesty, diligence, integrity and in compliance with the instructions given in relation to assignment.
Betty Blue manages relations with its employees on an equal and mutually respectful basis.
Employees shall avoid taking personal advantage of the relationship, acting in the sole interest of Betty Blue, and shall adequately safeguard and protect Betty Blue's property and personal data at their disposal for the activity entrusted to them with the same directives that apply to employees in the previous point.
Betty Blue requires its external collaborators to respect the ethical principles expressed herein, believing this to be of fundamental importance for the establishment or continuation of a business relationship.

e. Suppliers

Betty Blue requires its suppliers, subcontractors, laboratories, contractors and all those who participate directly or indirectly in the creation of value to respect the ethical principles expressed herein, considering this aspect of fundamental importance for the establishment or continuation of a business relationship. Every supplier, production or commercial partner or external collaborator must be informed of the existence of the Code of Ethics and the commitments required of them under the same.
Procurement processes for goods and services, supplies and subcontracts are characterised by the search for competitive advantage, equal opportunities for those involved, fairness and impartiality.
The selection of suppliers and the determination of purchasing conditions are based on the following criteria:

Objective assessment of the quality and capacity to provide and guarantee goods, services and benefits of an adequate level;
Duly documented availability of means, including financial means, organised structures, technical knowledge, skills and resources in relation to the intervention to be performed;
Professionalism of the interlocutor.

In supplying goods and services, Betty Blue's partners, employees and collaborators are obliged to:

Adopt objective and transparent evaluation criteria when selecting the supplier;
Not preclude anyone meeting the requirements from competing for the contract;
Observe the contractual conditions;
Maintain a frank and open dialogue with suppliers, in line with good business practice.

The conclusion of a contract with a supplier and the management of the relationship with that supplier is based on mutual clarity and fairness.

f. Privacy and personal data

In carrying out its activities, Betty Blue processes personal data, also of a sensitive nature, of its customers, employees and collaborators.
The databases managed by the company may contain personal data that are protected by legislation protecting the privacy, data that cannot be disclosed externally or data whose disclosure could cause damage to the company itself.
The Company requires that its employees and the employees of its partner companies undertake, within the scope of their duties, to ensure that personal data are processed in accordance with the legislation in force at all times and in compliance with the principles of lawfulness, correctness and transparency, limitation of purposes and storage times, integrity and confidentiality.
We ensure the confidentiality of the information in our possession; comply with the regulations on the collection, processing and storage of personal data; and refrain from seeking confidentiality through illegal means.
We are constantly striving to strengthen and improve our measures to protect the information and data we process, in all situations and in all ways. We respect the privacy of our customers, employees and all persons whose data are directly or indirectly processed by us.
We comply with European legislation on the personal data and privacy of our employees, collaborators, suppliers and users of our services. It is forbidden to disclose and/or divulge confidential information and sensitive data except in the manner and in compliance with the procedures established in the GDPR (EU Regulation No. 679 of 2016) on the protection of personal data.
It is in no way permitted for anyone who comes into possession of information of corporate interest and/or relating to any stakeholder to disseminate or use it outside the purposes for which it has been authorised or for purposes unrelated to the exercise of its activity.

4. Compliance with the code

Betty Blue undertakes to disseminate the Code of Ethics to all addressees.

a. Compliance with the rules contained in the Code of Ethics

Every addressee is required to be familiar with the rules contained in this Code of Ethics and the applicable rules governing the activities carried out within the scope of their role, deriving from the Law or from internal procedures and regulations.
Each addressee must also explicitly accept their commitments arising from the Code of Ethics:

Refrain from conduct contrary to the rules contained in the Code;
Refer to their superiors, or to the Supervisory Board referred to in Section 5.2, for clarification as to how they are applied;
Promptly report to their superiors, or to the Supervisory Board referred to in Section 5.2, any information, whether directly observed or reported by others, concerning possible violations of the Code, as well as any request made to them to violate them;
Cooperate with the bodies responsible for verifying possible violations;
Adequately inform any third party with whom they come into contact in the course of their work about the existence of the Code and the commitments and obligations it imposes on external parties;
Demand compliance with obligations that directly affect their business;
Take appropriate internal and, if within their competence, external action in the event of failure by third parties to comply with the Code.

b. Supervisory and Reporting Board

A Supervisory Board has been specifically set up and assigned the following tasks with regard to the implementation of the Code of Ethics:

Monitor the application of the Code of Ethics by stakeholders through the application of specific organisational rules and accept any reports provided by internal and external social stakeholders;
Report periodically to the Board of Directors on the results of the activities carried out, pointing out any significant breaches of the Code;
Advise on the revision of the most relevant policies and procedures to ensure their consistency with the Code of Ethics;
Propose periodic revisions of the Code of Ethics, where necessary.

Should they become aware of alleged violations of this Code of Ethics, or of conduct that does not comply with the rules of conduct adopted by the Company, all addressees must promptly report this by email to odv231@bettybluespa.com. The Supervisory Board shall proceed to verify the justification of the alleged violations, hearing, where appropriate, the person who made the report and/or the alleged perpetrator.
The Supervisory Board acts to protect whistleblowers against any form of retaliation, discrimination or penalisation, without prejudice to legal obligations and the protection of the rights of the Company and third parties, and to ensure the confidentiality of the whistleblower and of the facts being reported.
Reports can also be submitted through the whistleblowing channels activated and available at this link: www.segnalazioniwhistleblowing.it/wb/wb_esterni?code_az=1C138. In the event of unfounded, malicious whistleblowing, the sanctions set out in the adopted disciplinary system may be applied to the person responsible.

c. Violations and Sanctions

Compliance with the Code of Ethics is an integral part of the contractual obligations of addressees.
Breaches committed by Betty Blue's Directors, managers, employees and collaborators are subject to the company disciplinary system in force: conduct contrary to the Code will be sanctioned, with due respect for the right of defence, according to the severity of the conduct, on the basis of the provisions of the law and of the contract, and may constitute grounds for termination of contractual relations with addressees, should the fiduciary relationship be broken or should there be a serious breach of the duties of fairness and good faith in the performance of the contract.
Violations of the Code by employees are subject to the company rules on disciplinary sanctions, as well as, where applicable, the specific provisions of the Organisation and Management Model adopted pursuant to Legislative Decree no. 231 of 8 June 2001.
In particular, pursuant to Article 7 of the Workers' Statute and the applicable CCNL for Commerce, in the event of violation of the Code of Ethics, the Company may apply the following measures:

Verbal warning for minor faults;
Written warning for a repeat offence as referred to in point 1) above;
Fine in an amount not exceeding four hours of normal pay;
Suspension from pay and service for a maximum of ten days;
Disciplinary dismissal without notice and with the other consequences of reason and law.

The Company may not apply any disciplinary measure against the employee, other than a verbal warning, without first contesting the charge and hearing the employee's defence.
The disciplinary measure may not be applied until five days have elapsed since the written notification of the act giving rise thereto, during which the employee may present their justification.

5. 5. Amendments and additions

The Code of Ethics may be amended and supplemented by resolution of the Board of Directors of the Company, on the basis of applied experience and on the proposal of Supervisory Board.