CODICE ETICO

2 RULES OF CONDUCT

2.1 CONDUCT IN RELATIONS WITH STAFF

DLVSystem values its human resources, made up of an international research group with academic recognition and experience in technology transfer, as well as top talents from both academic and professional backgrounds.

• Staff selection and management: Recruitment is based solely on the alignment of candidates’ profiles with company needs, ensuring equal opportunities and applying objective, merit-based criteria, without discrimination. DLVSystem views training as a strategic element for personal and professional growth, providing clear job information and valuing expertise.

• Work environment: The company is committed to protecting the dignity of its employees, shielding them from psychological violence, harassment, and discrimination. Any form of marginalization or persecution (“mobbing”) is not tolerated.

• Health and safety: Workers’ health and safety are top priorities. DLVSystem is committed to providing a healthy and safe working environment.

• Employee duties: Employees must act in good faith, with diligence and loyalty, in compliance with this Code and internal company procedures.

• Conflict of interest prevention: Employees must refrain from activities that may appear to conflict with the company’s objectives and must immediately disclose any potential conflicts.

2.2 CONDUCT TOWARD CLIENTS

Relations with clients must be characterized by courtesy and availability, while safeguarding the company’s image. DLVSystem is committed to delivering cutting-edge AI solutions across various industries and ensures compliance with personal data protection regulations.

2.3 CONDUCT TOWARD SUPPLIERS

Procurement processes are based on transparency and efficiency. DLVSystem ensures that suppliers meet the required professional and legal standards. Suppliers are expected to comply with the law and this Code of Ethics.

2.4 CONDUCT TOWARD PUBLIC AUTHORITIES

Relations with public authorities must adhere to the principles of proper administration and impartiality. Corruption and illicit favoritism are strictly prohibited.

2.5 CONDUCT WITH OTHER STAKEHOLDERS

• Relations with shareholders: DLVSystem is committed to providing shareholders with necessary information and facilitating their participation in company decisions.

• Relations with organizations, political parties, and trade unions: Any funding or sponsorship must be transparent and comply with conflict-of-interest regulations.

• Relations with the press and media: External communications must be truthful and transparent, and media relations are reserved for authorized company functions. Offering payments or gifts to influence journalistic impartiality is not permitted.

3 INFORMATION MANAGEMENT

DLVSystem ensures the confidentiality of sensitive data and information in its possession, protecting data related to personnel, clients, and suppliers, and safeguarding the confidentiality of correspondence. Every employee is required to protect the confidentiality of information they access through their role and responsibilities.

4 BUSINESS CONDUCT

• Diligence and fairness in carrying out tasks and contracts: Contractual commitments must be fulfilled with diligence and fairness, avoiding the exploitation of loopholes or unforeseen events.

• Fair competition: DLVSystem recognizes the value of fair competition and refrains from collusive or abusive behavior.

• Anti-corruption: Any action aimed at unduly promoting company interests or undermining the impartiality of third parties is prohibited.

5 CORPORATE CONDUCT

• Accounting integrity: Every transaction must be managed accurately, transparently, and truthfully. Accounting records must be complete and easily retrievable.

• Gifts and hospitality: Gifts intended to obtain favorable treatment are not allowed, except for low-value items within normal business practices. Any offer to public officials that could influence their independence or judgment is forbidden.

• Protection of company assets and IT security: Company assets must be used responsibly and in accordance with their intended purpose. IT tools must be used correctly and lawfully, avoiding unauthorized access, duplication, or disclosure of third-party software or information.

6 CODE IMPLEMENTATION AND CONTINUOUS PREVENTION AND CONTROL MEASURES

6.1 REPORTING VIOLATIONS

Any violation of this Code of Ethics must be reported to the administrative office via regular mail (in a sealed envelope marked “confidential/personal”) or by email to amministrazione@dlvsystem.it. DLVSystem guarantees confidentiality and protection for whistleblowers from retaliation, provided the report is made in good faith.

6.2 SANCTIONING SYSTEM

Violation of this Code constitutes a disciplinary offense, punishable under applicable laws and/or the relevant National Collective Labor Agreement. The imposition of any sanctions is the exclusive responsibility of management, in accordance with current regulations.

6.3 PREVENTION AND CONTROL MEASURES

DLVSystem’s Code of Ethics serves as an ongoing, cross-functional prevention and control measure, outlining the guiding principles and standards of conduct for all collaborators. Knowledge of and compliance with this Code are considered essential for establishing and maintaining collaborative relationships with third parties. The company is committed to disseminating the Code among staff and stakeholders through dedicated training initiatives, ensuring continuous awareness of expected behaviors. Furthermore, the establishment of a whistleblowing mechanism and a disciplinary system provides constant oversight of ethical compliance, promoting the prevention of non-compliant behavior and enabling corrective action when necessary.

Key conduct principles — such as acting in good faith, with diligence and loyalty; ensuring transparency in procurement; respecting principles of proper administration and impartiality in public dealings; and exercising care and fairness in performing duties and contracts — apply across all operational areas and external relations of DLVSystem.