ORGANIZATION MODEL 231

Gaia Energy, as a result of the responsibilities taken upon with its code of ethics, has adopted an organization and management model from the Legislative Decree of June 8th, 2001, n. 231, which introduced the regulation of administrative responsibilities of juridical persons, societies and associations even when lacking physical persons connected to an offense (predicate offenses).

The Model adopted is consistent with the regulatory provisions and has been drawn up in line with the schemes also used for ISO 37001. It fully represents Gaia Energy’s spirit of transparency towards stakeholders and sense of responsibility in internal relations, thus offering better guarantees for efficient and correct management.

The Gaia Energy Model consists of a “General Part”, a section dedicated to the editorial criteria, and individual “Special Parts” prepared for different types of crimes and offenses to be prevented as updated on 31st December 2019. Any violation or suspected violation of Model 231/01 can be reported to the Supervisory Body of Gaia Energy SRL even anonymously and an email can be sent to the address: ufficiolegale@gaiaenergy.it or in paper to

Gaia Energy SRL

Organismo di Vigilanza

Via Ferrovie dello Stato SC

Gricignano di Aversa (CE)

Organization Model 231: Laws

LEGAL AREA CONTACTS

Legal area manager

Attorney Marianna QUARANTA

Telephone: +39 081.833.45.10

e-mail: ufficiolegale@gaiaenergy.it

Certified email: mariannaquaranta@avvocatinapoli.legalmail.it