CODE OF ETHICS

Introduction

EMU Group S.p.A. (hereinafter also the “Company”) founded in 1951, has established itself as an international reference company in the field of outdoor furniture thanks to constant research in technology, design and an industrial approach for the production of design furniture.

The context in which the company operates and the new challenges and increasingly large contexts have suggested formalising its rules of behaviour in a Code of Ethics, which clearly and unambiguously defines the values and ethical principles that EMU Group S.p.A. recognizes as essential elements of its corporate culture, to be taken as points of reference in the conduct of business and of any activity directly or indirectly related to the company.

This Code of Ethics (hereinafter also the “Code”), therefore, is the official document adopted by the Company in order to outline the set of values and principles that it undertakes to respect and enforce, in order to serve as a priority tool of business ethics aimed at directing the management of relations with the market, the territory and its stakeholders.

In addition, the Code represents one of the elements prepared by the Company to ensure effective prevention, detection and fight against violations of laws and regulatory provisions applicable to its business.

EMU Group S.p.A. interprets the concept of “Ethics” not only as a series of rules and conduct but as a modus vivendi and, therefore, as the ability to carry out its business activities with respect and protection of the interests of all individuals with whom the Company itself relates and with the protection of environmental resources and their conservation. The objective is to ensure that the fundamental values adopted by the Company are clearly defined and constitute a constant reference for everyone in carrying out their activities, also allowing the creation of a shared vision and culture. EMU Group S.p.A. – Code of Ethics – Page 4 | 23 Rev.02 – 08.09.2026

Recipients

The Company inspires its business, in addition to the necessary compliance with the laws, by the principles contained in this Code, declaring itself free from now on not to undertake or continue any relationship with anyone who demonstrates that they do not respect its content, violating its principles and rules of conduct. The Company therefore intends to share its principles with all the stakeholders with whom it interacts in order to achieve its objectives.

This Code therefore applies to Shareholders, Directors, Auditors, all employees of the Company, all employees of the Company, all external collaborators (such as project contract workers, temporary workers, consultants, intermediaries, partners in business relationships, agents, resellers), suppliers, sub-contractors, customers and all other individuals who for various reasons and at various levels come into contact with EMU Group S.p.A. or act in its name and on behalf of it (hereinafter the “Recipients”).

The Recipients undertake to behave in line with what is indicated in the Code of Ethics, to consult their manager and/or company representative regarding any doubts or possible interpretations of parts of the Code of Ethics and to report all violations to the same that they may become aware of. The Company therefore requires its business partners, suppliers, subcontractors, consultants, intermediaries, agents, resellers, customers and other parties with whom it has business relationships to share and respect, in the context of their activities and relationships with the Company, the principles and values contained in this Code of Ethics.

This Code is valid both in Italy and abroad, with the adaptations that may be necessary or appropriate due to the different contexts of the countries in which EMU Group S.p.A. is operating. If national law imposes stricter requirements than this Code, the provisions of local law apply.

In the event that even one of the provisions of the Code of Ethics conflicts with provisions set out in internal regulations or procedures, the Code of Ethics will prevail over any of these provisions. EMU Group S.p.A. – Code of Ethics – Page 5 | 23 Rev.02 – 08.09.2026

Good

faith

The Company bases its business and every interaction on the principle of good

faith and mutual loyalty. Every Recipient of this Code, whether internal personnel EMU Group S.p.A. – Code of Ethics – Page 6 | 23 Rev.02 – 08.09.2026

or business partner, must act based on the principle of good faith in the genuine conviction of acting correctly and with substantial respect for the rules and other subjects.

3.4. Impartiality and individual protection

The Company recognises that work has not only economic value but also social and existential value, and helps to give people a sense of purpose in their lives.

The Company conducts its business whilst avoiding discriminatory and opportunistic behaviour. In pursuing this purpose, it does not discriminate against sex, race, language, religion, political opinions, personal and social conditions.

EMU Group S.p.A. protects employees from psychological abuse or workplace bullying and combats any attitude or behaviour that is discriminatory or harmful to individuals, their beliefs or their inclinations. In particular, it is strictly forbidden, in the context of employment relationships, to engage in harassment of any kind or, more generally, to behave in a manner that is likely to undermine the smooth performance of the duties assigned or that is in any way detrimental to the dignity of the employee.

3.5. Development of human resources

The development of human resources and respect for their autonomy, whilst fully complying with current regulations, are fundamental principles for the Company. The governing bodies are committed to organising refresher and training programmes designed to enhance specific professional skills, with a view to maintaining and developing the skills acquired.

In order to better protect workers’ rights, the Company is committed to fully, impartially and consistently applying the relevant legislation and employment contracts, whilst rejecting and combating any form of exploitation, irregular employment or child labour, both within the Company and in its dealings with business partners.

3.6. Health and Safety

The Company considers the protection of health and safety at work to be a fundamental value and a shared responsibility, to which all those who work, in any capacity, for the Company must contribute. To this end, the Company ensures a healthy and safe workplace by assessing the risks to health and safety at work arising from its activities and implementing measures to prevent accidents, both during the course of work and the activities carried out, and as a result of them, whilst minimising, as far as is reasonably foreseeable, the hazards present in the workplace.

The Company operates in compliance with current legislation on health and safety at work and, in particular, with Legislative Decree No. 81 of 9 April 2008, as amended, ensuring that the preventive and protective measures required by law are implemented and promoting the continuous improvement of health and safety EMU Group S.p.A. – Code of Ethics – Page 7 | 23 Rev.02 – 08.09.2026

conditions in the workplace.

Every employee is required to comply with the provisions and preventative and protective measures adopted by the Company, to use the equipment and devices provided correctly, and to report promptly any hazardous conditions, deficiencies or risk situations encountered whilst carrying out their duties, in accordance with the procedures set out in the applicable company policies.

Health and safety protection also applies to employees, consultants, contractors, suppliers, customers and, more generally, all those who work or pass through the Company’s workplaces or who interact with it. The Company requires these individuals to comply with the applicable provisions and the security measures put in place, including by providing them with advance information on the risks and rules of conduct relevant to the activities carried out.

Everyone is expected to look after their own health and safety, as well as that of other people in the workplace who may be affected by their activities or behaviour, thereby helping to foster a practical and responsible culture of prevention.

3.7. Sustainability and environmental protection

The Company considers sustainability and environmental protection as key principles of its identity and growth strategy. Through a process of continuous improvement, the organisation is committed to consistently integrating environmental, social and governance (ESG) factors into all its day-to-day operations, promoting best practices that protect the ecosystem, enhance people’s wellbeing and generate a positive and lasting impact on the community in which it operates. This approach is based on the utmost transparency towards all stakeholders, including customers and suppliers, not least through the public sharing of results and milestones achieved in the field of sustainability, with a view to strengthening a relationship of mutual trust and shared responsibility for the future.

3.8. Respect for tangible and intangible assets

The protection and promotion of the Company’s assets, whether tangible, digital or intangible, are a fundamental value and a duty for everyone who interacts with the Company.

Every recipient, including employees, contractors, suppliers and customers, is directly and personally responsible for the protection, safekeeping and proper use of the company’s assets and resources entrusted to them by the Company or with which they come into contact.

Consequently, recipients must act in accordance with the procedures in place for the use and protection of the company’s tangible and intangible assets, and must refrain from any improper or negligent use that could result in a loss of efficiency of the company’s resources or cause damage to the Company. EMU Group S.p.A. – Code of Ethics – Page 8 | 23 Rev.02 – 08.09.2026

The Company operates in compliance with copyright and requires the same standard for its entire supply chain. All recipients are therefore prohibited from duplicating, distributing, reproducing or transferring copyright-protected works (for example, computer programmes, musical works and cinematographic works). In business dealings, suppliers and customers must refrain from any unauthorised conduct or use of the company’s name, logo or distinctive marks that could be detrimental to the Company’s image, standing or reputation.

The Company’s assets and resources, both tangible and intangible, also include information systems, accounts, login credentials, digital devices, software, databases, corporate networks, electronic archives, collaborative platforms, electronic communication tools, cloud services, data processing tools and any other digital resources made available by the Company or otherwise used in the course of its business.

The duty of care and fairness requires anyone who uses or accesses these tools – including external partners authorised to operate on the company’s channels and portals – to safeguard their security, ensuring the integrity, availability, confidentiality and authenticity of the information and data processed.

It is strictly forbidden to make any improper, unauthorised or unlawful use of digital resources, or to use the company network or tools for purposes unrelated to professional activities or to access websites of dubious moral content. Compliance with these provisions and the related information security measures is an essential prerequisite for ensuring secure, fair cooperation aimed at the mutual protection of information assets.

The correct use of digital and IT tools forms an integral part of the duties of diligence, fairness, loyalty and protection of the company’s assets required of all those to whom this Code applies. EMU Group S.p.A. – Code of Ethics – Page 9 | 23 Rev.02 – 08.09.2026

Rules of Conduct

The conduct of all recipients, both within and outside the Company, must always be based on respect for the values and principles set out in this Code; they must act in a manner that best reflects the Company’s code of conduct and the provisions of the Code.

4.1 Business management

4.1.1 Governance

The Corporate Bodies act and take decisions in full knowledge of the facts and independently, with a view to creating value for the Company whilst adhering to the principles of legality and fairness.

Decisions taken by members of the Corporate Bodies must be independent, that is to say, they must be based on their own independent judgement and must serve the interests of the Company.

The Company’s Directors are required to maintain and ensure transparent conduct in their dealings with the supervisory bodies in order to facilitate the proper performance of the activities falling within their remit.

Independence of judgement is a prerequisite for decisions taken by the Corporate Bodies; consequently, members must ensure the utmost transparency when managing transactions in which they have a particular interest. In these circumstances, the relevant laws and company regulations must be respected.

The procedures and protocols designed to prevent adverse events and the resulting potential negative impacts on the company’s situation are based on the Code of Ethics and are drawn up – or appropriately supplemented and amended – following an analysis of the company’s context.

The procedures and protocols are designed to ensure that the individuals within the organisation responsible for decision-making, authorisation and the execution of operations can be identified, and to prevent unlimited and/or excessive powers from being granted to any single individual. Furthermore, the traceability of every process relating to the company’s activities must be ensured, so that it is always possible to reconstruct, after the event, the reasons behind the decisions taken and the individuals responsible.

4.1.2 Relations with third parties

It is strictly forbidden to offer to third parties, either directly or indirectly, or to accept, any gifts and/or benefits (money, objects, services, favours or other advantages) which could be interpreted by an impartial observer as intended to EMU Group S.p.A. – Code of Ethics – Page 10 | 23 Rev.02 – 08.09.2026

secure an advantage – whether financial or otherwise – contrary to mandatory provisions of law, regulations and the principles of this Code.

Acts of commercial courtesy, such as gifts or hospitality, are permitted provided they are of modest value, offered in a public and transparent manner, and do not compromise the integrity or reputation of either party.

4.1.3 Relations with customers

The Company’s success and reputation are based above all on its ability to understand and meet the needs of its customers, whilst maintaining high standards of performance and reliability. To this end, EMU Group S.p.A. makes it a priority to accurately identify its customers’ needs. The Company provides accurate and comprehensive information about the services it offers, so that clients can make informed decisions; it maintains complete confidentiality regarding confidential information relating to its clients, whether this concerns the client’s strategic information or personal data, and uses such information solely for strictly professional purposes, subject to obtaining explicit authorisation. In return, customers are required to ensure the utmost confidentiality and to protect any information, documents, trade secrets and personal data relating to the Company, its staff and its activities from any unauthorised disclosure.

4.1.4 Relations with suppliers, subcontractors

and commercial intermediaries

The Company recognises the strategic and fundamental role played by suppliers, subcontractors and commercial intermediaries in ensuring the excellence and sustainability of its operations. The process of selecting and qualifying such parties is carried out in accordance with the principles of fairness, cost-effectiveness, quality, legality and respect for human rights, on the basis of objective assessments aimed at safeguarding the commercial and industrial interests of EMU Group S.p.A. and, in any event, at creating greater value for the company. Compliance by these parties with this Code is a necessary condition for the commencement or continuation of the relationship. The Company also adopts specific procedures to ensure that objective criteria are applied when awarding contracts and managing relationships with suppliers, subcontractors and commercial intermediaries, so as to guarantee transparency and fairness, whilst fully complying with explicit contractual commitments. EMU Group S.p.A. draws up these contracts in accordance with current regulations, ensuring they are fair, comprehensive and transparent, whilst endeavouring to anticipate any circumstances that could have a significant impact on the relationship established. The agreed remuneration must be commensurate with the service specified in the contract and payments may not be made to any party other than the contracting party, nor in a country other EMU Group S.p.A. – Code of Ethics – Page 11 | 23 Rev.02 – 08.09.2026

than that of the contracting parties, in order to safeguard tax transparency and prevent money laundering. EMU Group S.p.A. undertakes to maintain the strictest confidentiality regarding information concerning its suppliers, subcontractors and commercial intermediaries, and to use such information solely for strictly professional purposes, and in any event only following explicit authorisation.

4.1.5 Relations with public institutions

The Company bases and aligns its conduct on the principles of legality, fairness and transparency, so as not to induce the public administration to breach the principles of impartiality and sound administration to which it is bound. In the context of any business negotiations, a request or a relationship with the Italian and/or foreign public administration and with any other party, no conduct aimed at unlawfully influencing their decisions in order to secure an undue or unlawful advantage for the Company must be engaged in under any circumstances.

Any business relationships, whether of an economic or financial nature, with current or former employees of public administrations, whether Italian or foreign, as well as with their relatives and in-laws, must be managed in accordance with the applicable legislation and the principles of transparency and the prevention of conflicts of interest, and must be subject to prior assessment by the Company Management.

It is prohibited to use contributions, grants or funding obtained from the state, another public body or the European Communities for purposes other than those for which they may have been awarded, even if of modest value and/or amount. EMU Group S.p.A. condemns any conduct, by any person, consisting of promising or offering, directly or indirectly, gifts or other benefits (money, goods, services, favours or other advantages) to public officials and/or public service employees, whether Italian or foreign, or to their relatives, from which the Company might derive an undue advantage. It is also prohibited to induce public officials or public service employees, whether Italian or foreign, to use their influence over other individuals within the Italian or foreign public administration in order to secure an undue advantage for the Company.

In dealings with the public administration, each recipient is required to provide truthful, complete and accurate information, and to refrain from any conduct that might compromise the impartiality, independent judgement or integrity of the public official with whom they are dealing.

4.1.6 Relations with the Judicial Authority

The Company recognises the rule of law and respect for institutions as core values of its corporate and commercial culture.

EMU Group S.p.A. undertakes to cooperate actively in order to support the judicial authorities in any way they may require, and refrains from engaging in any conduct towards the parties involved that might, in any way, influence the EMU Group S.p.A. – Code of Ethics – Page 12 | 23 Rev.02 – 08.09.2026

manner in which the judicial authorities carry out their duties.

4.1.7 Relations with trade unions and political parties

The Company conducts all its dealings with political organisations, parties and trade unions in accordance with the highest standards of transparency, fairness and neutrality, rejecting any form of undue influence or favouritism.

Contacts with political and trade union organisations are, as a rule, restricted to authorised company departments and are conducted in accordance with the provisions of the current procedures. Any dealings with such parties are also guided by high standards of transparency and fairness. The Company is not permitted to make contributions to trade unions, political parties or their representatives, except where expressly permitted and provided for by law and, in the latter case, authorised by the relevant corporate bodies.

4.1.8 Relations with independent auditors and statutory auditors

EMU Group S.p.A. ensures that all dealings with the Independent Auditors and Statutory Auditors are conducted with the utmost professionalism, diligence, transparency, cooperation and willingness to assist. The Company also acts in accordance with the institutional role of these bodies and ensures that the required provisions and obligations are fully and promptly complied with, providing the necessary information in a clear, timely and comprehensive manner. In its dealings with Independent Auditors and Statutory Auditors, EMU Group S.p.A. undertakes to avoid any situation involving a conflict of interest and is committed to assessing in advance any assignment of duties other than their institutional functions that might compromise their independence and objectivity.

4.1.9 Relations with competitors

EMU Group S.p.A. intends to establish itself in the market by ensuring that its operations are conducted in full compliance with the principles of fair competition and the laws that protect it. The Company therefore undertakes to comply with the national and supranational regulations in force in the various areas in which it operates. No employee or contractor may take any action intended to unduly influence the market or the free determination of prices.

4.1.10 Intellectual property and the duty of confidentiality

EMU Group S.p.A. recognises the vital importance of intellectual property as a key asset of the Company and takes all appropriate measures to protect it. All employees and contractors of the Company, even after the termination of their employment, and in general all Recipients, are required not to disclose information concerning the Company’s technical, technological and commercial know-how, as well as other non-public data and/or information relating to the Company, unless such disclosure is required by law or is EMU Group S.p.A. – Code of Ethics – Page 13 | 23 Rev.02 – 08.09.2026

expressly provided for in specific contractual agreements under which the parties have undertaken to use such information for specifically agreed purposes. In particular, it is essential to treat ideas, models and other forms of intellectual property developed in the course of business with due confidentiality and to protect them.

EMU Group S.p.A. further undertakes not to carry out projects and/or produce products that may infringe the intellectual property, industrial property or copyright of third parties. Similarly, suppliers are required to guarantee full ownership and the lawful nature of the goods and technologies supplied to the Company, and customers are required to use the Company’s solutions and trademarks in full compliance with the agreed contractual limits, thereby promoting a commercial ecosystem based on fairness, legality and the mutual protection of intellectual property.

4.1.11 Conflict of interests

EMU Group S.p.A. respects the privacy of the recipients of this Code, including with regard to their personal activities in the economic and commercial spheres, provided that such activities do not conflict with the Company’s own interests or with the obligations undertaken and arising from the nature of the existing working relationship.

In this regard, all Recipients must avoid any situations, even potential ones, in which conflicts of interest might arise, and must refrain from seeking personal gain from any business opportunities arising from the performance of their duties. Furthermore, this Code prohibits any conduct on the part of the Recipients that seeks to exploit their position within EMU Group S.p.A., or information obtained in the course of their work, in order to create a conflict between their own interests and those of the company. It is also prohibited to accept or offer money, gifts or favours of any kind from individuals, companies or organisations that have, or intend to enter into, a business relationship with EMU Group S.p.A.

Anyone who finds themselves in a conflict of interest, even a potential one, is required to notify the Company Management immediately and to refrain from carrying out the activity in question until arrangements have been made to manage the situation. Where a conflict of interest or a combination of economic and family interests involves business partners, suppliers and customers are required to declare this promptly to their company contacts or via the official contact channels provided by the Company, in order to agree on appropriate contractual safeguards.

4.2. Personnel management

The Company recognises that people are a key asset to its development and promotes a working environment based on respect for the dignity, professionalism and rights of every individual, as well as on the principles of EMU Group S.p.A. – Code of Ethics – Page 14 | 23 Rev.02 – 08.09.2026

fairness, collaboration, inclusion and equal opportunities.

The Company contributes to the training and professional development of its employees and contractors by periodically offering them opportunities both to get to know one another and to share information about their respective work experiences, as well as other training initiatives, with the aim of promoting their growth and enabling them to develop their professional skills. Every employee and/or contractor must strive to create a working environment that is always stimulating and rewarding and which, therefore, promotes the application of the principles set out in this Code.

The Company condemns all forms of discrimination, harassment, intimidation or behaviour that undermines a person’s dignity, and promotes a working environment in which equal opportunities are guaranteed and individual skills and professional expertise are valued.

4.2.1. Recruitment, professional development, training and remuneration schemes

The processes of selection, recruitment, job classification, training, remuneration and career development are based solely on objective criteria centred on the professional and personal characteristics required to carry out the work in question and on the skills demonstrated in performing that work, so as to exclude any form of discrimination on the grounds of race, religion, origin, health, age or gender.

The information requested during the selection process is strictly related to the assessment of the aspects set out in the professional and psycho-aptitude profile, whilst respecting the candidate’s dignity, confidentiality and privacy, and complying with the applicable legislation on the protection of personal data.

The Company is committed to ensuring that, within its organisational structure, any objectives set for employees and contractors are focused on an achievable, specific, concrete and measurable outcome, and are linked to the timeframe envisaged for its achievement.

Decisions relating to selection, recruitment, job classification, training, appraisal, career development and remuneration must not be influenced by discriminatory factors or by factors unrelated to the skills, performance and professional requirements called for.

4.2.2. Company assets and digital assets

Each Recipient is required to use the company’s assets and resources to which they have access or which are at their disposal efficiently and in a manner that safeguards their value; to this end, they must act with due care, behaving responsibly and in accordance with the operating procedures established to regulate their use.

Any use of such assets and resources that is contrary to the interests of EMU Group S.p.A. is prohibited; in any event, any use that is unrelated to the purpose EMU Group S.p.A. – Code of Ethics – Page 15 | 23 Rev.02 – 08.09.2026

of the existing professional relationship or that may in any way cause alterations to or damage to the aforementioned assets is prohibited. By way of example, and without limitation, under no circumstances is it permitted to use company assets, and, in particular, company IT equipment, to commit or incite the commission of criminal offences, or to pursue any purpose that contravenes applicable laws or that may constitute a threat to public order, the protection of human rights or public decency. The Company’s employees are responsible for safeguarding the resources entrusted to them and have a duty to promptly inform the relevant departments of any threats or harmful incidents.

Company IT equipment must be used in accordance with the principles of diligence, loyalty, fairness, confidentiality and security. Any unauthorised or negligent use of devices, accounts, credentials, software, networks, digital archives, collaborative platforms, electronic communication tools, cloud services or other IT tools that may compromise the security, integrity, availability, authenticity or confidentiality of company information is prohibited.

Anyone accessing the information systems is personally responsible for ensuring the strict safeguarding of their login credentials, which must not be shared with third parties or used to grant access to unauthorised persons; it is also prohibited to circumvent the security measures in place or to access applications, folders or databases without explicit authorisation. It is prohibited to install, download, use or distribute software, applications, extensions, platforms, digital services or IT tools that have not been authorised by the Company or that do not comply with the applicable company procedures.

The use of the company’s digital resources must always be consistent with the activities carried out, the company’s interests, the instructions received and the organisational and technical measures adopted to protect the company’s assets and information.

Furthermore, both internal staff and business partners using the company’s channels have a specific duty to promptly inform the relevant departments in the event of the loss, theft or compromise of company devices; suspected unauthorised access; abnormal use of accounts or credentials; receipt of suspicious or potentially fraudulent communications; phishing attempts; malware infections, significant malfunctions or other circumstances likely to compromise the security of the company’s information systems.

4.3. Protection of health and safety in the workplace

In line with the principle set out in paragraph 3.6, the Company requires anyone working, collaborating or passing through its premises to strictly comply with current legislation and company procedures relating to health and safety.

Every employee, supplier and customer is expected to look after their own safety EMU Group S.p.A. – Code of Ethics – Page 16 | 23 Rev.02 – 08.09.2026

and that of others by behaving in a vigilant and responsible manner.

It is strictly forbidden to tamper with safety devices, carry out tasks outside one’s remit or engage in behaviour that may pose a risk. On the other hand, the correct use of safety devices is required, and there is an obligation to report promptly any fault or potential hazard encountered. Business partners must also actively cooperate in managing interference and ensure that their staff comply with the prevention standards and codes of conduct in force at the Company’s sites.

4.4. Protection of the environment

The Company carries out its activities in the knowledge that the rational adoption of measures to manage natural resources and the introduction, within its production system, of technologies that have a lower impact on the environment and public health, promotes appropriate respect for the environment.

In particular, EMU Group S.p.A. takes all appropriate measures to minimise the environmental impact of its activities, in line with applicable regulations and established best business practice. It also undertakes to implement measures aimed at raising awareness and fostering respect for the environment on the part of all Recipients. To this end, suppliers, customers and business partners are also required to comply with these standards and the applicable procedures, and to work actively together to minimise the environmental impact throughout the entire supply chain.

4.5. Communication and information management

4.5.1. Transparency of accounting records

When preparing accounting documents and data, reports or other corporate communications required by law and addressed to shareholders and the public, as well as in any records relating to the administration of the company, staff must adhere to the strictest principles of transparency, fairness and truthfulness.

In particular, all collaborators involved in the preparation of the aforementioned documents are required to verify, each within their respective areas of responsibility, the accuracy of the data and information that will subsequently be incorporated into the documents. The procurement and disbursement of financial resources, as well as their administration and control, must at all times comply with the approval and authorisation procedures laid down by the Company. Each accounting entry must accurately reflect what is recorded in the supporting documentation, which must be complete and verifiable.

4.5.2. Corporate communications

EMU Group S.p.A. is committed to providing all the information it is required to submit to the supervisory authorities (the Italian Revenue Agency, Customs Authorities, etc.) in a clear, timely, accurate and comprehensive manner. Only EMU Group S.p.A. – Code of Ethics – Page 17 | 23 Rev.02 – 08.09.2026

the company departments specifically designated for this purpose may carry out the aforementioned reporting activities to the supervisory authorities.

4.5.3. Relations with the media

Information relating to the Company and intended for the media may only be disclosed by the company departments authorised to do so, in accordance with current procedures and/or those to be implemented. Should the Recipients be asked to provide information or give interviews, they must notify the relevant department and obtain specific prior authorisation.

In any case, the communication of data or information to external parties must be truthful, transparent and such as to consistently reflect the image and strategies adopted by the Company, thereby fostering support for corporate policies.

4.5.4. Confidentiality

In the course of its business activities, EMU Group S.p.A. collects a significant amount of personal data and confidential information, which it undertakes to process in compliance with all applicable privacy and data protection laws in the jurisdictions in which it operates, as well as with best practice. To this end, the Company undertakes to maintain an adequate level of security in the selection and use of its information technology systems intended for the processing of personal data and information of a confidential nature.

Recipients, both internal and external, must not disclose, upload, enter, transfer, copy, store or otherwise make available personal data, confidential information, trade secrets, technical documentation, commercial information, data relating to customers, suppliers, collaborators or other contacts, credentials, content protected by intellectual property rights or other non-public company information via unauthorised digital channels, external platforms, personal accounts, unapproved cloud services, unauthorised artificial intelligence tools or other tools not validated by the Company.

The duty of confidentiality also extends to information that is processed, generated, analysed, handled or supported by means of digital tools, information systems, collaborative platforms, cloud services or artificial intelligence systems.

Recipients are required to ensure that documents, data and company information are shared exclusively with authorised parties, using tools approved by the Company and in accordance with the principles of necessity, proportionality, security and relevance to the business objectives being pursued.

It is understood that the duty of confidentiality remains in force even after the termination of employment, collaboration, supply, consultancy or any other contractual relationship with the Company.

4.5.5. Digital behaviour, cyber security and the responsible use of EMU Group S.p.A. – Code of Ethics – Page 18 | 23 Rev.02 – 08.09.2026

artificial intelligence

EMU Group S.p.A. recognises that digital technologies, information systems, electronic communication tools, databases, cloud services, collaborative platforms and artificial intelligence systems are essential resources for innovation, the conduct of business activities, and the protection of the Company’s tangible and intangible assets, its reputation, its know-how, business continuity and the proper management of relationships with customers, suppliers, employees, consultants, business partners and other stakeholders.

These resources must be used exclusively for lawful purposes that are authorised and consistent with the professional activities carried out, in full compliance with this Code, company procedures and applicable laws. This duty of digital diligence and prudence applies not only to internal staff, but also extends strictly to all business partners, suppliers and customers who interact with the Company’s systems, networks or platforms, requiring everyone to refrain from conduct that could compromise the confidentiality, integrity and availability of the Company’s information assets. To safeguard cyber security, no user is permitted to access systems or databases without explicit authorisation, to share their personal login details with third parties, or to circumvent the security and monitoring measures put in place. It is also prohibited to install unauthorised software, to use company networks for unlawful or fraudulent purposes, or to disseminate content that is false, manipulated or offensive to human dignity.

Every Recipient is obliged to report promptly to the relevant company channels any cyber incident, anomaly, loss or theft of devices, unauthorised access, misuse of credentials, suspicious communication, phishing attempt, malware infection, data breach or suspected data breach, as well as any other event that may affect the security of the company’s information systems, data or information.

The concealment, delayed reporting or incomplete reporting of incidents, anomalies or events relevant to cyber security, data protection, business continuity or regulatory compliance constitutes conduct contrary to the principles of loyalty and integrity set out in this Code of Ethics.

With regard to artificial intelligence systems, including generative AI tools, the Recipients must use such technologies only where authorised and in accordance with company guidelines, applicable regulations and the principles of transparency, accountability, human oversight, accuracy, confidentiality, non-discrimination, security and the protection of fundamental rights.

It is prohibited to input personal data, confidential information, trade secrets, technical documentation, contractual information, data relating to customers, suppliers, employees or business partners, strategic information, credentials, economic, financial or industrial data, as well as other non-public business information, into unauthorised artificial intelligence systems, unless expressly EMU Group S.p.A. – Code of Ethics – Page 19 | 23 Rev.02 – 08.09.2026

authorised by the Company and in accordance with the applicable procedures.

Results generated by artificial intelligence systems should not automatically be regarded as reliable, complete, accurate, up to date or suitable for business use. The Recipients remain responsible for verifying, assessing and validating these results before they are used in any documents, communications, decisions, analyses, processing, internal operational activities or external communications.

Artificial intelligence systems must not be used to generate, disseminate or support content that is false, misleading, discriminatory, offensive, unlawful, defamatory or manipulative, nor to infringe intellectual property rights, confidentiality obligations, data protection regulations, contractual commitments, company procedures or the principles set out in this Code of Ethics.

The use of artificial intelligence systems cannot replace the responsibility, professional judgement, diligence and human oversight required of the Recipients in the performance of their duties. Where the use of such tools affects activities of significance to the Company, the Recipients must ensure that the information used and the results produced are properly verified, traceable and subject to control.

The use of digital technologies and artificial intelligence must always be consistent with the Company’s values, with the protection of human dignity, with the safeguarding of the Company’s assets, with compliance with applicable legislation, with the protection of personal and corporate data, and with business continuity. EMU Group S.p.A. – Code of Ethics – Page 20 | 23 Rev.02 – 08.09.2026

Implementation

and Penalty System

5.1. Knowledge and implementation

The Company is committed to promoting awareness and understanding of this Code of Ethics amongst all those to whom it applies, through appropriate communication, information and, where appropriate, training initiatives.

The Code of Ethics is published on the Company’s website (www.emu.it) and made available via the corporate channels deemed most appropriate. Employees and contractors are made aware of the Code as part of the induction process and, where necessary, through specific information and training initiatives.

All Recipients are required to be familiar with the principles and rules of conduct set out in this Code and to act in accordance with them, as well as with the applicable legislation and the relevant company procedures and instructions.

Recipients are required to contribute, within the scope of their responsibilities, to the effective implementation of the principles of the Code and to report promptly any conduct that breaches them or could compromise their application.

The Company promotes awareness of and the correct application of the provisions of this Code, including in relation to digital behaviour, cyber security, data protection, the confidentiality of company information and the responsible use of artificial intelligence systems.

Recipients are required to comply with the applicable company policies on digital matters, to take part in any information or training sessions organised by the Company, and to seek clarification from the relevant departments should they have any doubts regarding the correct use of tools, platforms, data, information systems or artificial intelligence technologies.

Under no circumstances may the absence of specific instructions justify conduct that contravenes the principles of prudence, diligence, confidentiality, security, legality and fairness set out in this Code.

Any amendments and/or additions to this Code must be made in the same manner as that adopted for its initial approval.

5.2. Compliance Officer

The Board of Directors appoints a Compliance Officer to oversee the application of the Code; this officer coordinates as necessary with the relevant bodies and departments to ensure the correct implementation and adequate monitoring of the principles of the Code.

The Compliance Officer is specifically responsible for ensuring that the Code is promoted and made widely known, and that it is properly implemented and kept up to date, taking action (either on their own initiative or following a report) to prevent or identify any breaches of the Code through the relevant company EMU Group S.p.A. – Code of Ethics – Page 21 | 23 Rev.02 – 08.09.2026

departments (e.g. human resources, legal, etc.). In carrying out their duties, the Compliance Officer shall have unrestricted access to company data and information relevant to the performance of their duties. The Recipients are required to cooperate fully in facilitating the performance of the Compliance Officer’s duties.

As part of their duties to monitor the application and updating of the Code, the Compliance Officer may also put forward proposals to supplement or amend the rules of conduct relating to digital matters, taking into account technological, organisational and regulatory developments, as well as risks relevant to the Company.

5.3. Reporting Obligations

Any Recipients who, in the course of their work or by virtue of the duties they perform, become aware of conduct, acts or omissions that contravene the principles and rules of conduct set out in this Code are required to take action in accordance with the procedures laid down in the applicable company policies.

Reports concerning breaches of this Code that fall within the scope of the legislation on whistleblowing must be made via the channels established by the Company, which, in accordance with current legislation and relevant best practice, guarantee the confidentiality of both the whistleblower and the person against whom the report is made. These channels can be accessed via the following link: https://emu.segnalazioni.net/.

Reports concerning breaches of this Code that do not fall within the scope of the Whistleblowing Procedure shall be sent to the Compliance Officer via the designated email address responsabilevigilanza@emu.it or by post to the Compliance Officer (Responsabile delle Vigilanza) at EMU Group S.p.A. – 06055 Marsciano (PG) – Via L. Einaudi – Zona Ind.le Schiavo snc.

The Compliance Officer is the contact person appointed by the Company to receive reports of breaches of this Code and, where necessary depending on the nature of the report, liaises with the relevant corporate bodies and departments to carry out the necessary investigations and take any resulting action.

It remains the case that reports relating to specific events, anomalies or incidents must be made in accordance with the procedures and through the channels set out in the relevant company procedures. In particular, Recipients are required to report promptly any incidents or anomalies relating to the misuse of digital tools, unauthorised access to information systems, the loss or theft of company devices, compromised credentials, breaches or suspected breaches of personal or company data, cyber security incidents, and the unauthorised or improper use of artificial intelligence systems.

Reports must be made promptly, comprehensively and in good faith, avoiding any concealment, alteration, omission or unjustified delay in the provision of relevant information.

The Company ensures, in accordance with the applicable legislation and the company’s whistleblowing procedure, that the identity of the whistleblower, the EMU Group S.p.A. – Code of Ethics – Page 22 | 23 Rev.02 – 08.09.2026

person concerned or any other individuals mentioned in the report, as well as the content of the report and the related documentation, is kept confidential. Any acts or behaviour that are retaliatory, discriminatory or otherwise prejudicial, carried out as a result of a report, are prohibited and subject to penalties, within the limits and in accordance with the provisions of the applicable legislation.

5.4. Disciplinary system

Compliance with the provisions of the Code forms an essential part of employees’ contractual obligations pursuant to and for the purposes set out in Articles 2104, 2105 and 2106 of the Italian Civil Code.

Any breach of the provisions of this Code of Ethics by the Company’s staff may constitute a breach of the fundamental obligations of the employment relationship or a disciplinary offence, in accordance with the procedures laid down in Article 7 of the Workers’ Statute (where and to the extent applicable), with all legal consequences, including in relation to the continuation of the employment relationship, and may also give rise to claims for damages.

With regard to the penalties that may be imposed, the provisions of the disciplinary system adopted by EMU Group S.p.A. shall apply. Breaches will be assessed and, where the conditions are met, dealt with promptly and without delay through the adoption – against those responsible for the breaches, where deemed necessary to protect the company’s interests and in accordance with the provisions of the current regulatory framework – of appropriate and proportionate disciplinary measures, regardless of whether such conduct constitutes a criminal offence and irrespective of whether criminal proceedings are instituted in cases where it does constitute a criminal offence.

Disciplinary measures for breaches of the Code are taken by the relevant departments, in coordination with the Compliance Officer, in accordance with the laws in force and the relevant national or company-level employment contracts.

Any breach of the principles and rules set out in this Code by directors, members of corporate bodies and other individuals holding positions of responsibility within the Company shall be assessed by the relevant corporate bodies, taking into account the nature and seriousness of the breach and the responsibilities associated with the role held, and appropriate measures permitted by law and the Company’s articles of association shall be taken.

A breach of the Code of Ethics by persons outside the Company may, in accordance with the specific contractual clauses included in letters of appointment, contracts or commercial agreements, result in the early termination of the contractual relationship, without prejudice to the right to claim compensation before the competent courts should such conduct result in actual damage to the Company.

Breaches of the provisions relating to the proper use of digital tools, information systems, company data, IT security measures and artificial intelligence systems may constitute a breach of this Code of Ethics and may result in the application of EMU Group S.p.A. – Code of Ethics – Page 23 | 23 Rev.02 – 08.09.2026

disciplinary measures, contractual remedies and any further action provided for by law, internal procedures and applicable agreements.

Such breaches will be assessed taking into account, amongst other things, the nature of the conduct, whether the breach was intentional or negligent, the role and responsibilities of the person involved, the potential or actual damage caused to the Company, as well as exposure to legal, regulatory, IT, data protection or reputational risks.

The following, by way of example and without limitation, constitute conduct relevant for the purposes of applying the disciplinary system: unauthorised access to systems or data; the unauthorised sharing of credentials; the circumvention of security measures; the use of unauthorised software, platforms or services; the unauthorised disclosure of confidential information; failure to report, or delayed reporting of, IT incidents or anomalies; the misuse of artificial intelligence tools; the unauthorised manipulation, alteration or deletion of data, documents, records or logs; as well as any other conduct likely to compromise the security, confidentiality, integrity, availability or traceability of company information and systems.

For parties outside the Company, any breach of the provisions of this Code relating to the use of digital tools, cyber security, data protection, confidentiality and the use of artificial intelligence may, in the cases provided for by the relevant contractual clauses and applicable legislation, result in the application of the contractual remedies provided for, including the termination of the relationship, without prejudice to the Company’s right to compensation for any damages suffered.