Star7 S.P.A.

Lobbying Governance

AI Extracted Evidence Snippet Source

##### Governance della sostenibilità GRI 2-12

The Consiglio di Amministrazione of STAR7 approves the Bilancio di sostenibilità and is committed to ensuring the updating of its knowledge, the involvement of stakeholders for the management of impacts, and the supervision of the reporting process in terms of sustainability, particularly concerning the identification and management of negative economic, environmental, and social impacts, potential or actual." [...] "##### Processi di comunicazione e conflitti di interesse GRI 2-15
GRI 2-16

As recalled in the Codice Etico, all activities of the STAR7 Group must always avoid situations where the involved parties may find themselves in a conflict of interest. Therefore, all employees of the STAR7 Group companies, in performing their duties on behalf of the Group, must pay particular attention not to participate in social activities that may lead to situations of conflict of interest, i.e., any situation that may somehow involve the personal interests of the individual or other subjects connected to them.

The Group companies require the prompt communication to the Group's managers or the Organismo di Vigilanza of any situation that, even potentially, is aimed at determining a conflict of interest. All potential conflicts must be communicated to their managers so that they can prevent the actual determination of such a situation by all means at their disposal.

Furthermore, potential conflicts of interest are prevented and mitigated by the overall system of governance tools and through the related-party procedure. The Consiglio di Amministrazione is tasked, taking into account the reports and observations of other corporate bodies, with periodically evaluating, at least every three years, the effectiveness of the procedure and the need and/or opportunity to proceed with a revision of the same." [...] "##### La condotta responsabile del business GRI 2-23
GRI 2-26

Modello di organizzazione, gestione e controllo D.Lgs. 231/2001

The Modello di organizzazione gestione e controllo ex D. Lgs.231/2001 (the "Modello 231") was adopted by the parent company STAR7 S.p.A. to guarantee and ensure conditions of compliance with the law, correctness, clarity, and transparency in the conduct of all business activities. The Modello 231 consists of a General Part and a Special Part relating to the various types of offenses relevant under the Decree that the Group could risk committing in its activity. The General Part contains the cardinal principles of the Model, the Organismo di Vigilanza, and the system of training and dissemination of the Model among the recipients. The Special Part is divided into sections. The various sections are aimed at outlining the principles to which the corporate protocols adopted (or to be adopted in the future) by the Company must be inspired. In particular, each Section of the Special Part is articulated in: a) description of criminal offenses; b) identification of sensitive processes in relation to the types of Offense; c) definition of general principles of conduct; d) identification of operational principles. The Special Part also describes the sanctioning system.

The Codice Etico constitutes an integral part of the Model.

As required by the reference legislation, an Organismo di Vigilanza (OdV) has been appointed, which carries out monitoring activities on the functioning, application/conformity of operations to the protocols of the Model, and takes care of its updating. The Modello 231 defines the information flows to and from the OdV.

The Model is available on the website [Corporate Governance | Modello 231.](https://www.star-7.com/sites/default/files/paragraph/download/field_file/2021-12/STAR7%20-%20modello%20di%20organizzazione%2C%20gestione%20e%20controllo_0.pdf)

It should be noted that, in addition to the parent company, the subsidiary STAR7 Printing has also adopted its own Modello 231.

https://www.star-7.com/sites/default/files/paragraph/download/field_file/2023-06/Bilancio%20di%20Sostenibilita%CC%80_STAR7%202022.pdf