Code of Ethics

CODE OF ETHICS OF FUTURA LAW FIRM S.T.A.R.L. SOCIETÀ BENEFIT

Background

  1. Futura Law Firm S.t.A.R.L. S.B. (hereinafter referred to as "Futura") is a company between lawyers pursuant to Article 4bis of the Law of Lawyers and has since its incorporation assumed the status of a benefit company pursuant to Law 280 of 2015 paragraphs 376-383;

  2. as a benefit company, Futura has a duty to act sustainably, responsibly and transparently;

  3. as a benefit company, Futura has assumed, in its corporate purpose, the duty to pursue certain objectives of common benefit that inspire, along with other fundamental principles, this code of ethics (the "Code of Ethics") and which is made public so that Customers, Suppliers and those who come into contact with Futura can know it by being able to tune in and collaborate with Futura;

  4. the values by which Futura is inspired are (in no particular order of importance): sincerity, cooperation, freedom, kindness, mutual trust, helpfulness, care for people and activities to be carried out, respect for the law, solidarity, respect for each other, justice, good manners, attention to each other's needs, confidentiality, honesty, freedom of expression, patience, protection of motherhood, fatherhood, and diversity.

  5. the three ESG (Environmental Social Governance) criteria and the goal of meeting them inspired the drafting of the Code of Ethics;

  6. all those who are permanently part of Futura's structure, whether they are partners, directors, employees, collaborators or permanent professionals are the recipients (the "Recipients") of the Code of Ethics in the performance of the services subject to Futura's assignment and otherwise on behalf of and/or in the interest of Futura (the "Performances").

All this being said, the following are the guiding principles of coexistence, collaboration and participation in Futura.

PRINCIPLES RELATED TO THE ENVIRONMENTAL COMPONENT (ENVIRONMENTAL)

  1. Environmental protection

Recipients, in the performance of their Services, are required to limit damage to natural systems, avoid waste and sub-optimal use of energy or resources, limiting environmental impact, recycling waste and making those with whom they come into contact for work purposes aware of this as far as possible.

Recipients are encouraged to use more environmentally friendly means of transportation, such as the train, instead of more polluting ones, reducing physical travel and promoting online connections where the type of performance allows and is not adversely affected.

Futura is committed within the scope of Performance to financially support the choice of greener solutions, and Recipients are invited to offer solutions and suggestions in this regard.

Recipients are encouraged to use recycled plastic, recycled paper, and to use compostable and less polluting materials, and Futura is committed to financially supporting work requirements in this regard.

Recipients are invited to take part in internally organized training meetings on environmental protection and climate change.

PRINCIPLES RELATED TO THE HUMAN (SOCIAL) COMPONENT

  1. Addressees of the Code of Ethics

Recipients are expected to scrupulously abide by the Code of Ethics when performing Services and are urged to take into account the principles of behavior set forth herein in the course of their private lives as well.

Entering into a stable working relationship with Futura implies knowledge of and compliance with the Code of Ethics.

The Code of Ethics is in addition to, and supplements, the Forensic Code of Ethics, which is mandatory for all lawyers working in Futura and does not replace it.

  1. Duties of Conduct for Recipients

The pursuit of the personal and professional satisfaction of those who take part in Futura as Recipients, envisaged in Futura's corporate purpose, entails that Futura ensures a stimulating professional commitment balanced with respect for the personal, family, social and leisure needs of each person, including through flexibility and differential treatment where necessary that allows the pursuit of substantial equality of treatment as well as enhancement of professionalism, autonomy, self-determination of each person and self-awareness.

In the event of personal problems, Recipients are invited to report them to one of Futura's Board of Directors so that, while respecting any confidentiality agreed upon, the Board of Directors can implement measures and take the most appropriate initiatives to try to make the moment or period of difficulty compatible with the commitment made to Futura.

In the event of dissatisfaction for any reason, Recipients are invited to bring their discomfort to the attention of one of the Board of Directors so that the Board of Directors can, while respecting the confidentiality that may have been agreed upon, try to find the most suitable solution that is compatible with the request received and the structure of Futura.

Recipients are invited to respond to questionnaires and interviews that may be submitted so that the Board of Directors has a current and complete awareness of the degree of satisfaction of Futura's permanent professionals.

Recipients, in the performance of Services, are expected to respect the principle of knowledge sharing, so as to enable other Recipients also to learn and learn notions useful to each other's professional growth.

Recipients are asked to respect vacations and rest days and vacation periods by avoiding on those days and in any case during the hours between 9 p.m. and 8 a.m. - unless truly urgent - sending communications and phone calls that are related to paperwork.

The "right to disconnect" during the hours indicated in the preceding paragraph and on public holidays, rest days and holidays remains unaffected.

Unless otherwise agreed, the professional relationship with Futura stipulates that every quote to Clients is agreed upon beforehand between the professionals involved in the service and that remuneration is proportionate to the professional contribution made to the practice in question: in this way, the effort and time devoted by each person to an activity is valued and those who-for personal reasons-don't feel they are making a significant professional contribution are allowed to be free in their choice in the knowledge that it does not generate unfair and disproportionate treatment.

Also in relation to the trust that characterizes relationships, Recipients are encouraged to lend their support as compatible with their expertise in favor of another Recipient who manifests a need or requirement for which the aforementioned expertise may be useful.

Recipients, depending on their skills and availability, may occasionally be asked to provide services and support, even unpaid, for the best internal functioning of Futura and the best collaboration among all.

As an exception to the criteria agreed upon with the Recipients for remuneration, in the event of actual economic need that does not have to be documented, the Board of Directors, maintaining confidentiality on the point, may decide to advance the remuneration to the Recipient who requests it, consistent with the Company's financial and economic availability.

  1. Relations with customers and performance of services

Customers are a key element of Futura's development and growth.

The Company rejects all forms of incompatibility, corruptibility and conflict of interest and is committed to guaranteeing Clients confidentiality and maximum transparency in rates and fees, including through clear and as comprehensive as possible quotes.

Recipients are expected to perform the Performances with competence, dedication, diligence, professionalism, care and attention, studying and investigating in depth the subject they are dealing with and proposing to Clients, where useful and appropriate, innovative solutions that create a positive impact in the Client's business and needs.

If, for personal or organisational reasons, this is not possible, a different deadline must be agreed with the customer. Punctuality of delivery must always be respected or, if this is not possible, it must be indicated to the client by agreeing a new deadline.

It is advisable that the Customer always receives a reply to his communications within a few hours, even if only interlocutory, in order to confirm that the communication has been read and that the request will be dealt with within the agreed time, without prejudice to the provisions of the following paragraph.

Unless otherwise agreed upon with Clients or in cases of true urgency, it is discouraged on the part of Recipients to send communications or contact by telephone during holidays and during the hours between 9 p.m. and 8 a.m., and Recipients have the right not to accept contact and not to provide feedback to communications and telephone calls that may be received from Clients during those hours and days.

Customers are required to maintain behavior in line with this Code of Ethics.

PRINCIPLES RELATED TO THE ORGANIZATION (GOVERNANCE) COMPONENT

  1. Respect for values and conduct

Recipients are expected to employ kindness toward those who interact with them, whether they are employees, professionals, consultants, colleagues, associates, customers, suppliers or third parties with the aim of making the work climate collaborative and positive, and to promote this attitude among the same parties.

Any form of discrimination on the grounds of language, religion, country, origin, gender, sexual orientation and age is prohibited, both in Futura's internal relations and in relations with third parties, including the choice of professionals, consultants, suppliers and clients.

Futura does not support political parties, committees or movements financially or in any other way.

Recipients must base their conduct on the values and principles set forth in this Code of Ethics.

Futura invests its economic resources in the best conduct of its business, in the constant improvement of the skills and abilities of the human capital involved, in the well-being and satisfaction of the latter, and in the pursuit of its goals of common benefit. Accordingly, it does not intend to invest in aspects that it does not consider necessary to its goals such as a particularly prestigious structure, invasive marketing, and awards and recognition that are lacking in shared motivation.

  1. Entities nonprofit and benefit corporations

Futura has in its corporate benefit object the collaboration and synergy with nonprofit organizations and businesses and companies that are preferably benefit or otherwise have a purpose aligned and synergistic with that of the Company and therefore should be preferred for collaboration over other non-aligned entities for equal performance and quality.

  1. Rates subsidized

Futura has in its corporate object benefit the provision of its activities at particularly subsidized or even symbolic rates for the benefit of individuals or legal entities that, lacking adequate funds, appear to the Company to be deserving of assistance and advice regarding Futura's matters and expertise.

Anyone in Futura, asked for such an activity, has the right to refuse Performance in the knowledge that this unavailability-if repeated-could be evaluated as a reason for not renewing the partnership.

  1. Courses

Futura has in its social benefit object the provision to promote, organize and carry out events and courses, including free of charge, for the benefit of interested third parties and the local community to promote culture in innovation, sustainability and corporate social responsibility.

Recipients are encouraged to promote and take part in such initiatives.

  1. Members

Shareholders, when they do not take part in the management or part of the management, have the right to request information on the same from the directors, and the directors are required to provide timely and comprehensive clarifications and explanations, while always ensuring maximum transparency of management and operation of the company for the benefit of the shareholders through the use of clear and shared tools, methodologies and procedures.

  1. Headquarters

As much as Futura has a physical registered office, available to Recipients consistent with each person's needs, the structure envisioned by Futura's founders does not allow for individual and exclusive physical space for Recipients: the goal is to allow Recipients the best management of their time and space, the containment of structure costs in favor of increased remuneration and resources for other needs, and the agility of the structure itself that allows for serious and unpredictable situations that require rapid downsizing.

  1. Procedures

Recipients are expected to be familiar with and scrupulously comply with deliberate procedures (with particular but not exclusive reference to privacy regulations, anti-money laundering, conflicts ofinterest and professional secrecy) and always available in the sharedvirtual memory.

  1. Sanctions

Alleged violation of the principles set forth in the Code of Ethics may be reported by anyone, including those outside the Company, to the Board of Directors, which will carry out the appropriate checks and evaluations.

Violation of the principles set forth in the Code of Ethics will be sanctioned with an initial verbal warning by the Board of Directors or the other Board members if perpetrated by a Board member and, in more serious cases, may result in the termination of the collaboration contract or, if perpetrated by one of the Board members, will be reported to the corporate structure for appropriate action.

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The Code of Ethics was drafted during the first year after Futura's incorporation with the input of all Recipients present in Futura and, shared with them, is published on the Company's website on February 18, 2022, on the occasion of the completion of the first year since incorporation.

With a view to continuous evolution and improvement, the Code of Ethics was revised by all partners, directors and permanent professionals present in Futura in October 2023.

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DECALOGUE OF KINDNESS IN THE FUTURE

These are purely work-related tips on the premise that kindness is a powerful form of human interaction for positive relationships that enhances mutual understanding.

Addressing people while smiling

A smile does not always represent our inner state of mind but nevertheless can be used in our approach to others. Sometimes smiling may require a great deal of effort but it will condition our disposition by offering a feeling of well-being to both the giver and the receiver. A smiling person stays imprinted more easily. This attitude should not be a way of hiding one's possible unhappy condition. And beware that the presence or absence of a smile can also be detected in a telephone conversation.

Putting an intention when asking "how are you?"

Too many times it is an automatic interchange, lacking the will to really know a person's mood and physical state. Even sometimes one hopes that the answer will contain the same automatism: "fine." Instead it must be a sincere question, trusting in a sincere answer that might lead to a brief excursus on the condition of our interlocutor (a fairly well might lead us to discreetly ask for reasons). If we really do not want to talk, it is even better not to ask the question.

Remembering important happenings in a person's life that we have been informed about

There are not many, our memory can handle it. If someone was recently married or had a recent birth, it is kind to remember it some time later and ask about it. But even more so, if someone has had a health problem or a great sadness, we try to remember it and direct our questions and comments so that they understand that we remember.

Do not always accompany your requests with haste and urgency

If everything is urgent it means that nothing is urgent or there is a problem. If every request has to be fulfilled right away it may be because we suffer from the "everything and now" syndrome that makes us unable to wait or that we have a problem with internal organization that prevents us from dealing with paperwork at the right time with the necessary and sufficient time to handle it properly. Either way, it is unacceptable to make colleagues and co-workers pay for our own disorganization. If we constantly reason about our approach marked by urgency, we will find that most of the time we can put it aside for both ourselves and others and that on other occasions it is caused by our own mistakes. And on the few times when we ask our colleagues to do something urgently, we will explain why and apologize.

Resist with gentle firmness the rudeness of others

While politeness has an extremely broad meaning, rudeness also has many facets and does not consist only of using rude and uneducated words. No one should respond to rudeness with rudeness but has a duty to himself or herself to reject unjust insults, verbal aggression, and unjustified demands (e.g., performing tasks with urgency: see point above). The reaction must be composed and polite but must be a firm rejection.

Never skimp on compliments and endorsements for colleagues and co-workers

They should not be affected and empty thanks, but thoughtful and deserved appreciations possibly with specific references so as to foster growth for all.

Comment and accept honest and well-founded criticism and grievances

In the case of justified expressions of discontent, from whomever they come, firm in the rejection of all rudeness, it is incumbent to listen, to comment but also to accept with intellectual honesty the criticism received because it is a way to improve oneself and improve one's performance. To be humble does not mean to nullify one's own value: on the contrary, it is essential to know one's own qualities and abilities in order to always enhance them, without this ever resulting in presumption (which implies an assumption of something that is not) and in the rejection of remarks and criticism.

Always recognize the merit of people who took part in a project or practice

Always give thanks for the help received and remember it

Make every effort to be available quickly if someone asks us to contact them or explain the reasons why we have to delay

This has nothing to do with urgency, but it is willingness to listen and confrontation.

Listen carefully and respectfully

Respect is an important form of kindness and is also embodied in the attention we pay to the people talking to us. Better to make clear from the outset the time frame you have and be completely focused in that time than to spend hours thinking about other matters considered more urgent or relevant .