The present Ethical Code (hereafter the “Code”) expresses the ethical commitment and responsibility of conducting business and corporate activities, and defines the set of values and principles, as well as behavioral guidelines which must be observed by the administrators of Sorgente Società di Gestione del Risparmio Spa (hereafter “Company” or “SGR”), all the persons associated by working relationships to the Company, in addition to all the employees no matter what their affiliation.

The adherence to the norms contained in the Ethical Code is essential to the proper operation, reliability, reputation and image of SGR.

All activities are carried out in the in compliance with the law within a context of fair competition with honesty, integrity, correctness and good faith, in the respect of the legitimate interest of the clients, employees, shareholders, commercial and financial partners as well as the community in which the company operates. Furthermore, all those who work of the SGR, with discrimination and exceptions, are committed to observe these principles in the realm of their own tasks and responsibilities. In no way will the belief of acting to the benefit of SGR or any other Company of the Sorgente Group justify the adoption of behavior in contrast with such principles. All those that act within or in the interest of the Company, without discrimination and exceptions, are moreover committed to observe and implement these principles within their tasks and responsibilities. In addition, this commitment demands that also the subjects with which the Company operates in any way must in their own right adhere rules and conduct inspired by the same values.