VISION AND VALUES

NAITEC's mission is to be a leader in the design and development of software for the integrated management and optimisation of airport processes and services, developing innovative solutions and providing services with high levels of quality, responsibility and ethics.

NAITEC's vision is to be a key player in the market for information systems, supporting the management of transport and mobility services, guaranteeing the users of our systems efficient operations, and a high-quality experience for the travellers served.

CODE OF ETHICS AND CONDUCT

In carrying out its business, NAITEC's goal is to create value for its stakeholders, helping to ensure that its customers can carry out their business as an airport operator or ground service provider in accordance with the public interest and the guidelines laid down for airports and handlers in national and international planning. In addition, NAITEC:

• - complies with the applicable EU, national, regional and local regulations, and the provisions issued by the competent bodies;
• - respects the legitimate interests of customers, suppliers, employees, investors, and partners;
• - complies with the principles set out in the SAVE Group's Code of Ethics and Conduct;
• - requires all personnel to comply with the principles and rules of conduct set out in the Code of Ethics and Conduct.

ORGANISATION, MANAGEMENT AND CONTROL MODEL, AS PER LEGISLATIVE DECREE 231/2001 (“MODEL 231”)

As set out in the Group's Code of Ethics, the Company complies with all of the ethical principles whose observance ensures that business is conducted in compliance with the law and without prejudice to the legitimate expectations of stakeholders concerning the Company's operations.

Accordingly, the Company has adopted an Organisation, Management and Control Model as per Legislative Decree 231/2001 (the '231 Model'), which is integrated into its own internal control and risk management system, and consistent with the guidelines of Confindustria (Confederation of Italian Industry) and good market and industry practices.

SAVE Group has adopted its own Model 231, in particular to prevent, according to criteria of suitable organisational diligence and minimisation of the inherent risk, the committing of unlawful conduct by its directors, employees, and collaborators in any capacity, as well as to avoid entering into relations with business partners the ethical integrity of which is, or appears to be, compromised, or who do not adhere to appropriate ethical principles when conducting their businesses.

All the procedures and internal rules applicable from time to time in force - including the Group's internal rules - are to be considered an integral part of the Company's overall Organisation, Management and Control Model.

Indeed, since all employees are called upon to fully comply with these procedures, all internal procedures and rules are also to be regarded as instrumental to ensuring compliance with the principles to the fulfilment of which the rules introduced by Legislative Decree No. 231/2001, together with related legislation, are aimed.

The Model, described and comprised in a complex set of documents approved by the Company's Board of Directors, consists of the following main elements: Group Code of Ethics; Descriptive Document of the Organisation, Management and Control Model as per Legislative Decree 231/2001; Supervisory Board; Disciplinary System and related sanctioning system; Training and Communication Plan; Internal Procedures and regulations.

The Descriptive Document of the Organisation, Management and Control Model as per Legislative Decree 231/2001 in turn consists of 231 Risk Analysis, General Part (“Parte Generale”), downloadable from the link below, and Special Provisions (“Parte Speciale”).

The Supervisory Board, a body set up within the Company and appointed by the Board of Directors, has the task of supervising the operation of and compliance with the Model, as well as ensuring that it is updated.

General Part of Naitec's Modello 231 

WHISTLEBLOWING – INTERNAL REPORTING CHANNEL

The recipients of the 231 Model, third parties, and, in general, all stakeholders having relations or carrying out business with the Company, are obliged to promptly send to the Company, using the channel deemed most appropriate: - substantiated reports of unlawful conduct, relevant under Legislative Decree 231/2001, and based on precise and consistent facts, or of violations of the organisation and management model of the company, of which they have become aware by reason of the tasks they perform or their relations with the Company; - other actions, conduct or events that may lead to the committing of unlawful acts, or in any case to the violation of rules, regulations and other provisions of the law or prescriptions of the competent Authorities; - any other violation of company procedures or regulations, including violations of the Code of Ethics or Model 231.

Several channels can be used for reporting, namely: paper mail or e-mail, verbal reports through face-to-face meetings, and the use of the alternative online channel that allows for both written and voice-recorded reports, while guaranteeing the confidentiality of the reporter's (whistleblower's) identity.

SAVE Group has indeed implemented an alternative channel for handling whistleblowing reports (the 'internal reporting channel'), which, by using computerised means, guarantees the confidentiality of the whistleblower's identity in accordance with current regulations and good market practice.

The alternative channel for handling reports is operated on a service independent of the company's IT systems, and allows the whistleblower to interact with the company confidentially, obtaining the statutory responses; it also allows whistleblowers to transmit verbal reports by voice recording.

The alternative channel for handling reports is consistent with the requirements of the law and the GDPR as regards protecting the identity of the reporter and the confidentiality of the transmission of information, which is also protected by encryption.

Management system for whistleblowing reporting: https://aeroportinordest.segnalazioni.net