Code of Ethics pursuant to Legislative Decree 231/2001

1. Introduction and Purpose

The present Code of Ethics outlines the principles, values, and rules of conduct that guide Ales Market Research srl (hereinafter, "Company") in carrying out its activities. It is an integral part of the Organization, Management, and Control Model adopted pursuant to Legislative Decree 231/2001 and serves as a binding reference point to guide daily decisions and conduct. The purpose of the Code is to prevent unlawful or non-compliant behavior, promote a corporate culture based on integrity, responsibility, and transparency, and strengthen the trust of clients, suppliers, collaborators, institutions, and the community. In case of interpretative doubts or situations not expressly covered, each recipient is required to contact their supervisor, the competent function (e.g., Human Resources, Compliance/Privacy), or the Supervisory Body (ODV) for guidance and clarification.

2. General Ethical Principles

The Company operates in full compliance with applicable laws and regulations (principle of legality), avoiding any form of wrongdoing or shortcuts. Every interaction with customers, suppliers, collaborators, and institutions is based on honesty, fairness, and loyalty: this translates into commitments kept, accurate and complete information, and a rejection of any corrupt practices, even indirect ones. Transparency guides the management of processes and internal and external communication, through traceable decisions, accurate documentation, and clear information flows. Confidentiality is rigorously protected: personal and company data are processed according to the principle of minimization, for lawful purposes and with appropriate security measures, in compliance with the GDPR (Reg. EU 2016/679) and national regulations.

The protection of individuals is at the heart of our culture: we promote equal opportunities, an inclusive environment, and respect for everyone's dignity, without discrimination based on gender, age, origin, creed, orientation, health status, disability, or other personal conditions. As a market research company, the Firm pays particular attention to methodological integrity, data quality, and accuracy in the representation of results, avoiding manipulations or misleading interpretations. We are aware of our social and environmental responsibility: we adopt sustainable practices, reduce environmental impacts, and encourage responsible behavior along the value chain. We believe in fair competition, respect for intellectual property, and the protection of informational assets; we promote fair relationships with third parties, based on objective criteria of quality, ethics, and merit.

3. Recipients

The Code is binding for members, directors, members of corporate bodies, employees at any level and with any type of contract, external collaborators, consultants, business partners, and suppliers, as well as anyone acting in the name or on behalf of the Company. The recipients are required to know the contents of the Code, participate in training initiatives, and, where provided, sign a declaration of acknowledgment and acceptance. In contracts with suppliers and partners, we include ethical clauses that require compliance with the Code (or equivalent standards) and provide remedies in case of violation. The selection and evaluation of third parties consider, in addition to economic and technical criteria, ethical behavior and regulatory compliance, including health and safety profiles, data protection, and respect for the fundamental rights of people involved in research activities and supply chains.

4. Expected behaviors

The daily behaviors of each recipient must be consistent with the principles of the Code and contribute to the Company's reputation and credibility. This applies to internal operations, relationships with clients and suppliers, interactions with Public Administration, and any other professional context, including the use of digital tools and external communication channels (e.g., social media) when one can be associated, even indirectly, with the Company.

4.1 Internal Relations

We promote a work environment based on respect, listening, and collaboration. Discrimination, harassment, or abusive behavior of any kind is not tolerated; any issues should be reported promptly through the designated channels. Communication is characterized by clarity and constructiveness, promoting teamwork, knowledge sharing, and peaceful conflict management. The use of company resources (e.g., time, material goods, IT devices, systems, and data) is conducted responsibly and in accordance with internal policies on cybersecurity, data protection, expenses, and travel, as well as approval procedures. The use of digital channels and social media must be professional and not harm the Company's image; confidential information must not be shared without authorization. We are committed to a culture of feedback and continuous improvement, where mistakes and reports become opportunities to learn and strengthen internal controls.

4.2 Relations with the Public Administration

Relations with the Public Administration (PA) are conducted with the utmost respect for the law, transparency, and fairness. It is prohibited to promise, offer, or accept money, gifts, benefits, or other forms of advantage to unduly influence decisions or obtain preferential treatment; facilitation payments and behaviors that, even if only in appearance, could constitute undue influence are not allowed. The management of tenders, contracts, authorizations, inspections, contributions, and public funding is carried out through official channels, with complete, truthful, and traceable documentation. It is mandatory to adhere to internal procedures for selecting intermediaries and consultants involved in relations with the PA, ensuring task segregation, compliance checks, and recording of relevant interactions (e.g., formal meetings) according to company policies. Any non-compliant behavior must be immediately reported to the designated channels and the Supervisory Body (ODV).

4.3 Conflict of Interest

Each recipient must avoid situations where personal, family, or financial interests could potentially interfere with the impartiality of decisions made in the Company's interest. Examples of conflicts include: undertaking paid assignments with clients or suppliers; holding shares or positions in companies that have or could have dealings with the Company; favoring relatives or acquaintances in selection or purchasing processes; accepting gifts, hospitality, or other non-modest advantages. Anyone who identifies a potential conflict is required to promptly report it to their manager and the ODV (or the competent function) and to refrain from related decisions or activities until further instructions are received. Gifts and courtesies can only be accepted or offered if they are of modest value, in line with lawful commercial practices, transparent, and consistent with internal policies, always respecting the absolute prohibition of unduly influencing decisions, particularly in dealings with public authorities.

4.4 Data Management

The processing of personal and business data must be lawful, fair, and transparent, in compliance with the GDPR and national regulations. We collect only the necessary data, retain it for the strictly necessary time, and protect it with appropriate technical and organizational measures. In the field of market research, we adopt methodologies that prioritize anonymization or pseudonymization, adequately inform the data subjects, and ensure the exercise of their rights. Access to data is allowed only to authorized individuals for legitimate purposes; transfers outside the EU and the use of cloud providers occur in compliance with legal requirements and after a risk assessment. All recipients are required to maintain the utmost confidentiality on confidential information, know-how, strategies, price lists, analysis models, and any other informational assets of the Company and its clients. Document management must ensure integrity, completeness, accuracy, and traceability, avoiding falsifications, alterations, or untruthful records.

4.5 Safety and Environment

The Company is committed to ensuring a safe and healthy work environment in compliance with Legislative Decree 81/2008, promoting training, information, and instruction, as well as the active prevention of accidents and injuries. Everyone is required to follow safety procedures, properly use equipment and devices, promptly report risk situations or near misses, and participate in emergency drills. Environmental protection is a shared value: we prioritize sustainable choices, efficient energy use, proper waste management, waste reduction, and, where possible, lower-impact solutions even in digital activities (e.g., optimizing stored data, remote meetings when appropriate). In activities at clients' sites or in the field, we adopt behaviors respectful of the context and local rules, coordinating with contacts to ensure safety, continuity, and quality of the service provided.

5. Whistleblowing and Reporting

ALES_Market_research_srl@registerpec.itAnyone who becomes aware, even in good faith and based on reasonable suspicions, of violations of this Code, the Model 231, or other company regulations/policies is required to report them without delay. Reports can be submitted through dedicated and protected internal channels [e.g., secure portal/channel, email: PEC: ALES_Market_research_srl@registerpec.it] and, in cases provided by law, also through the external channels of the competent Authority (e.g., ANAC) according to Legislative Decree 24/2023. The Company ensures the confidentiality of the identity of the whistleblower, the person involved, and the content of the report; protection is guaranteed against any form of retaliation, discrimination, or penalization related to the report made in good faith. Malicious or manifestly unfounded reports are prohibited. Reports are managed by designated functions and the Supervisory Body with criteria of impartiality, timeliness, and traceability, in compliance with privacy regulations and internal procedural timelines; the outcomes are communicated in ways compatible with confidentiality needs and the protection of the rights of the parties involved.

6. Disciplinary System

Violation of the Code of Ethics, Model 231, or related company procedures results in the application of disciplinary measures proportional to the severity, intent, recurrence, and consequences of the behavior, in compliance with applicable regulations, the relevant National Collective Labor Agreement, and the guarantees of due process. Sanctions may include, for example: verbal or written warnings, suspension, demotion, up to dismissal for just cause in the most serious cases. For directors and auditors, measures may be determined by the corporate bodies; for suppliers, partners, and consultants, it may lead to contract termination, compensation for damages, and exclusion from future collaborations. The disciplinary system is communicated to the recipients, applied consistently, and tracked; the measures taken also consider corrective effects and the strengthening of controls to prevent the recurrence of violations.

7. Supervisory Body (ODV)

ALES_Market_research_srl@registerpec.itThe Company has established a Supervisory Body endowed with autonomy, independence, professionalism, and continuity of action, tasked with overseeing the effectiveness and compliance with Model 231 and this Code, proposing updates, and managing information flows with company functions. The ODV receives and evaluates reports, conducts document and on-site checks, requests information and access to documents and systems, respecting organizational prerogatives and privacy and security regulations. The ODV reports periodically to the Board of Directors and the Control Body, prepares an annual activity plan, and may utilize internal expertise or qualified external consultancy. ODV contacts: ALES_Market_research_srl@registerpec.it.

8. Approval, Dissemination, and Update

The present Code of Ethics was approved by the Sole Administrator/Board of Directors on February 9, 2026, and comes into effect on the same date. The document is published on the company website, made available to all recipients, and integrated into the phases of onboarding, periodic training, and management of relationships with third parties. The Company promotes the widest dissemination of the Code, also through targeted training sessions and, where appropriate, versions or summaries in English. Any updates will be adopted in the event of regulatory or organizational changes, as well as following the results of monitoring and audit activities; each new version will be promptly communicated and made available. Management is called upon to set a concrete example of adherence to the values of the Code, promoting its consistent application throughout the organization.

The Sole Director and Legal Representative:

Tommaso Pronunzio

Milan 02/09/2026