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ORGANISATION, MANAGEMENT AND CONTROL MODEL

Laboratorio Farmaceutico SIT S.r.l.  (the ‘Company’) has adopted an organisation, management and control model (the ‘Model’) in compliance with the provisions of Legislative Decree no. 231 of 8 June 2001 (the ‘Decree’), and the Farmindustria Guidelines.

The Model was approved by the Company’s Board of Directors on 27 January 2022.

The Company has always been sensitive to the need to ensure conditions of fairness and transparency in the conduct of business activities to protect the organisation and corporate image, the reliability and integrity of Group companies and the expectations of its stakeholders. To this end, the Company has deemed the adoption of the Model to be in line with its values, as a valid instrument to raise awareness among all those who work in the name and on behalf of the Company in the performance of their duties, as well as to prevent the risk of committing the offences mentioned in the Decree.

In implementing the reference legislation, a Supervisory Board was established with the task of supervising the proper functioning of the Model, its effective compliance and its updating; reports of possible violations of the Model and/or relevant offences under the Decree may be addressed to the Supervisory Board at the following dedicated address: organismodivigilanza@sit-farmaceutici.com.

Organisational, management and control model of Laboratorio Farmaceutico S.I.T. S.r.l.

WHISTLEBLOWING

CODE OF CONDUCT

Laboratorio Farmaceutico SIT S.r.l. (the ‘Company’) has adopted a code of ethics (the ‘Code of Ethics’) that constitutes an integral part of the organisation, management and control model adopted by the Company in accordance with the provisions of Legislative Decree No. 231 of 8 June 2001 and the Farmindustria Guidelines.

The Code of Ethics contains the principles and rules of conduct aimed at preventing the predicate offences to which all those who collaborate in any capacity with the Company must adhere. This document highlights and makes concrete the Company’s corporate culture and reinforces the values it is committed to handing down over time.

TRANSPARENCY

SIT Laboratorio farmaceutico (SIT Pharmaceutical Laboratory), adhering to Farmindustria, is subject to accepting and respecting the Code of Conduct.

The Code of Conduct is an agreement between the pharmaceutical industries adhering to Farmindustria voluntarily approved in compliance with the relevant statutory rules and with the rules dictated by the Codes of Conduct of the European and International Federations of the pharmaceutical industry (EFPIA and IFPMA), and aimed at regulating the relations between the industries and between them and the scientific and health world.

The Code of Conduct regulates the obligation of transparency of transfers of value between pharmaceutical companies, Healthcare Professionals and Healthcare Organisations.

Every pharmaceutical company, in fact, must document and make public every year, through a special Form, the transfers of value carried out directly or indirectly with Healthcare Professionals and Healthcare Organisations.

Below are the Value Transfers, broken down by year:

Trasferimenti di Valore 2021
Trasferimenti di Valore 2022