Code of Ethics

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

Background

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

(B) as a benefit company, Futura has a duty to act in a sustainable, responsible and transparent manner;

(C) as a benefit company, Futura has assumed, in its corporate purpose, the duty to pursue certain objectives of common benefit which inspire, together with other fundamental principles, this code of ethics (the "Code of Ethics");

(D) the three ESG (Environmental Social Governance) criteria and the objective of respecting them inspired the drafting of the Code of Ethics.

Inview of the above, the following are the guiding principles for coexistence, collaboration and participation in Futura.

Addressees of the Code of Ethics

All those who are permanently part of the structure of Futura, whether they are partners, directors or professionals (the "Addressees"), are obliged to scrupulously respect the Code of Ethics when they carry out services that are the subject of assignment to Futura and in any case on behalf and/or in the interest of Futura (the "Services") and are invited to take into account the principles of conduct set out herein also in the course of their private lives.

Entering into a stable partnership 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 Conduct, which is compulsory for all lawyers working with Futura and does not replace it.

Values and conduct

Recipients are required to use kindness towards those who interact with them, whether they are employees, professionals, consultants, colleagues, partners, customers, suppliers or third parties, with the aim of making the working environment collaborative and positive and to promote this attitude among those same subjects.

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

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

The other values that must inspire the conduct of the Addressees are: respect for the law, solidarity, respect for others, good manners, attention to mutual needs, confidentiality, honesty, freedom of expression, patience, mutual trust, protection of motherhood and fatherhood.

Futura invests its economic resources in the best performance of its activity, in the constant improvement of the competences and skills of the human capital involved, in the well-being and satisfaction of the latter and in the pursuit of its objectives of common benefit. Consequently, it does not intend to invest in aspects that it does not consider necessary for the objectives set, such as a particularly prestigious structure, invasive marketing, awards and recognitions that are not reliably reflected.

Employees and Professionals

The pursuit of the personal and professional satisfaction of those who take part in Futura as employees and permanent professionals, provided for in Futura's corporate purpose, requires that a stimulating professional commitment is ensured, balanced with respect for the personal, family, social and leisure needs of each individual, also through flexibility and differentiated treatment where necessary that allow the pursuit of substantial equality of treatment as well as enhancement of professionalism, autonomy, self-determination of each individual and self-awareness.

In the event of personal problems, the Addressees are invited to report them to one of Futura's Board of Directors so that, in compliance with the confidentiality that may have been agreed, the Board of Directors can implement the 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 whatsoever, the Addressees are invited to bring their discomfort to the attention of one of the Board Members so that he or she can, in compliance with any confidentiality agreed, try to find the most suitable solution that is compatible with the request received and Futura's structure.

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.

The Addressees, in the performance of the Performances, are bound to respect the principle of knowledge sharing, so as to allow also the other employees and permanent Professionals of Futura to learn and learn notions useful for the professional growth of each one.

Recipients are invited to respect public holidays and rest days and the holidays of colleagues and employees, avoiding on those days and in any case during the hours between 9 p.m. and 8 a.m. - except in cases of real urgency - sending communications and telephone calls relating to files.

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 envisages that each estimate to Clients is agreed beforehand between the professionals involved in the service and that the remuneration is proportionate to the professional contribution made to the practice in question: in this way the effort and time dedicated by each person to an activity is valued and those who - for personal reasons - do not feel they can offer a significant professional contribution are allowed to be free in their choice in the knowledge that this does not generate unfair and disproportionate treatment.

Also in relation to the trust that characterises the relationships, the Addressees are invited to lend their support insofar as it is compatible with their skills in favour of another permanent collaborator of Futura who manifests a need or a requirement for which the aforementioned expertise may be useful.

The Addressees, in relation to their own skills and availability, are invited to provide services and support, even unpaid, for the best internal functioning of Futura and the best collaboration among all.

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 strongly encouraged to use more environmentally friendly means of transport, such as trains, instead of more polluting ones, reducing physical travel and promoting online connections where the type of service allows and is not adversely affected.

Recipients are encouraged to use recycled plastic, recycled paper and to use compostable and less polluting materials.

Relations with customers and performance of services

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

The Company rejects any form of incompatibility or conflict of interest and undertakes to guarantee its Clients confidentiality and maximum transparency in rates and fees, also through clear and as comprehensive as possible estimates.

Recipients are required to perform the Services with competence, professionalism, care and attention, studying and studying in depth the subject they are dealing with.

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 with the Customers or in cases of real urgency, it is not advisable for the Addressees to send communications or make telephone contact during holidays and during the hours between 9 p.m. and 8 a.m. and the Addressees have the right not to accept contact and not to provide feedback to communications and telephone calls that may be received from Customers during those hours and days.

Non-profit organisations and benefit societies

Futura has in its benefit social object the collaboration and synergy with non-profit organisations and companies preferably benefit or that have a purpose aligned and synergic with that of the Company and that therefore, with equal performance and quality of the same, should be preferred for collaboration over other non-aligned entities.

Subsidised tariffs

Futura's object of benefit includes the provision of its services at particularly favourable or even symbolic rates to natural or legal persons who, lacking adequate funds, appear to the Company to be deserving of assistance and advice with regard to Futura's matters and competences.

Anyone in Futura who is requested to do so has the right to refuse the Service in the knowledge that this unavailability - if repeated - could be assessed as a reason not to renew the relationship.

Courses

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

The addressees are invited to promote and take part in such initiatives.

Members

When Shareholders do not take part in the management or in a part of the management, they have the right to request information on the same from the directors and the latter are obliged to provide timely and exhaustive clarifications and explanations, always ensuring maximum transparency in the management and operation of the company in favour of the shareholders through the use of clear and shared tools, methodologies and procedures.

Headquarters

Although Futura has a physical registered office, available to the Recipients according to their needs, the structure envisioned by Futura's Founders does not allow for an individual and exclusive physical space to be offered to the Recipients: the objective is to allow the Recipients the best management of their time and space, the containment of structural costs in favour of an increase in remuneration, and the agility of the structure itself that allows it to cope with serious and unpredictable situations that require rapid downsizing.

Procedures

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

Sanctions

Any alleged breach of the principles set out in the Code of Ethics may be reported by anyone, including those from outside the Company, to the Board of Directors, which will carry out the necessary checks and assessments.

Violation of the principles set out in the Code of Ethics shall be sanctioned with an initial verbal warning by the Board of Directors or the other Directors if committed by a Director and, in the most serious cases, may lead to termination of the collaboration contract or, if committed by one of the Directors, shall be reported to the corporate structure for appropriate measures.

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