Legislative Decree no. 231 of 08 June 2001 (Legislative Decree 231/2001) introduced a significant addition in the Italian legal system, providing for a form of liability, defined as administrative, but comparable to criminal liability, to be borne by legal persons, companies or associations, including those without legal personality, for certain crimes committed in the interest or to the advantage of the Entity, by individuals in "senior" positions or by those who are subject to the management or supervision of the latter.

This liability is independent of the criminal liability of the individual who committed the crime and is therefore in addition to it.

The administrative liability of the Company is excluded if the Company has adopted and effectively implemented, prior to the commission of the crimes, suitable organisation and management models to prevent the crimes.

The Company has adopted an Organisation, Management and Control Model (Model 231), by a resolution of the Board of Directors, which formalises, in a nutshell, the set of measures aimed at preventing the crimes set forth in Legislative Decree 231/2001, as part of the activities identified as sensitive to the potential risk of the commission of an offense referred to in that decree.

The Company has also established a collegial Supervisory Board, appointed by the Board of Directors and endowed with autonomous supervisory and control powers, with the task of supervising the operation of and compliance with the Model and ensuring that it is updated.

The principles and rules expressed in Model 231 are consistent with those set forth in the Group Code of Ethics adopted by the Company by resolution of the Board of Directors. The Code of Ethics expresses, among other things, lines and principles of conduct aimed at preventing the crimes set forth in Legislative Decree 231/01 and expressly refers to Model 231 as a useful tool for operating in compliance with regulations. The Code of Ethics should therefore be considered as an integral part of this Model 231 and a fundamental tool for achieving the Model's objectives.

If a person becomes aware of violations, even suspected violations, of Model 231 or the Code of Ethics itself, they may promptly report them in detail to the Iren Supervisory Board (SB) or to their superiors or to the Internal Audit and Compliance Department.

Reports to the Supervisory Board, based on precise and circumstantiated facts, can also be made anonymously by accessing the dedicated portal, sending an e-mail to the mailbox accessible only to members of the Supervisory Board or a letter to the attention of the Chair of the Supervisory Board at "Studio dell'Avv. Catellani", Via Guido da Castello 33, 42121 Reggio Emilia (RE), Italy. Reports to the Iren Internal Audit and Compliance Department can be made at internalaudit@gruppoiren.it.