ETHICS

TRANSPARENCY

The Company's management is based on a traditional model, with the Board of Directors responsible for the ordinary and extraordinary management of the company. The Company also has a Board of Auditors, as a control body, which consists of five members: the Chairman, two Auditors and two Alternate Auditors. The legal audit is entrusted to the external auditing firm, and there is a Special Prosecutor, representing the Company and appointed by the Company as well. SUPERVISORY BODY (SB) Fulgar has adopted the Organisational and Management Model 231 (OMC 231), with subsequent establishment of a Supervisory Body (SB), composed of two external members and one internal member, with the task of supervising the functioning and observance of the OMC 231 and to take care of its updating.

ADOPTION OF SPECIFIC PROCEDURES

The Supervisory Board (SB) has arranged for the adoption of specific Operating Procedures, carrying out annual checks on their correct application, using external resources if necessary, and following a detailed schedule drawn up in the Verification and Internal Control Plan. Any findings are subsequently submitted to the Board.


CODE OF ETHICS

At the same time as MOG 231 came into force, Fulgar adopted a Company Ethical Code, which is shared with all suppliers and delivered to all employees of the Company during the signing of the employment contract. The Code manifests the fundamental principles of honesty, moral integrity, correctness, transparency, objectivity and respect for the individual personality that Fulgar follows in the pursuit of its corporate objectives and in all its internal and external relations. The objective is a sustainable business development through respect and cooperation, protection and the benefit of all parties involved.

DEDICATED COMMUNICATION CHANNEL

The Supervisory Board also monitors compliance with the Code of Ethics and handles any reports of violations thereof that may be received from both employees and third parties, ensuring all necessary guarantees of anonymity and confidentiality, through a dedicated communication channel.


INTEGRAL PARTS OF GOOD MANAGEMENT

For Fulgar, the Model 231, the Supervisory Board and the Code of Ethics are fundamental to good company management. They are a reference for the protection against environmental, social and governance risks, both real and possible, that could clash with the company strategy, activities and internal and external relations. In fact, the MOG 231 is composed of a generic part and a special part in which the activities at risk and the relevant company areas are described.

HEALTH AND SAFETY POLICY AVAILABLE

The Code of Ethics also allows the identification of potential human rights risks, such as the risk of discrimination, while the Supervisory Board and the reporting procedures allow the management of their actual occurrence. In addition to these tools, specifically, Fulgar relies on its own Occupational Health and Safety Policy with the relative Occupational Safety Manual. For the definition of environmental risks, such as the risk of production-related accidents and their negative consequences, the Company uses the Environmental Analysis Document (DAA) and the relative analyses. Monitoring and managing risk situations related to ESG (Environment, Society and Management) issues is fundamental to Fulgar's sustainable business vision. It is a key criterion for achieving a competitive advantage in an industry where sustainability is essential.