Code of Ethics approved by resolution of the BoD on 21.11.2012

Third approval for revision pursuant to resolution of the BoD on 12.09.2014

Second approval for revision pursuant to resolution of the BoD on 12.05.2014

CODE OF ETHICS

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CONTENTS

INTRODUCTION .................................................................................................................................................................. pag. 3

GENERAL PROVISIONS ...................................................................................................................................................... pag. 5

Clause 1 - Scope of the Code of Ethics .....................................................................................................................................pag. 5

Clause 2 - Addressees of the Code of Ethics ............................................................................................................................pag. 5

Clause 3 - Distribution and implementation of the Code ........................................................................................................pag. 6

Clause 4 - Principles on which company operations are based .............................................................................................pag. 6

Clause 5 - Contractual value of the Code ................................................................................................................................pag. 8

TRANSPARENCY OF ACCOUNTS REPORTING AND INTERNAL CONTROLS .......................................................................... pag. 9

Clause 6 - Books and records .....................................................................................................................................................pag. 9

Clause 7 - Internal controls .........................................................................................................................................................pag. 9

CONDUCT OF THE TOP MANAGEMENT ............................................................................................................................. pag. 11

Clause 8 - General principles ....................................................................................................................................................pag. 11

Clause 9 - Conflicts of interest ....................................................................................................................................................pag. 11

PERSONNEL POLICIES ........................................................................................................................................................ pag. 12

Clause 10 - General principles ..................................................................................................................................................pag. 12

Clause 11 - Recruitment of personnel .......................................................................................................................................pag. 12

Clause 12 - Management of personnel ...................................................................................................................................pag. 13

Clause 13 - Environment, Safety and health of workers ............................................................................................................pag. 13

Clause 14 - Right to personal safety ..........................................................................................................................................pag. 14

Clause 15 - Duties of personnel..................................................................................................................................................pag. 15

BUSINESS ETHICS................................................................................................................................................................ pag. 17

Clause 16 - General principles ...................................................................................................................................................pag. 17

Clause 17 – Gifts and other benefits .........................................................................................................................................pag. 17

Clause 18 - Relations with customers and private contractors ...............................................................................................pag. 18

Clause 19 - Relations with suppliers and subcontractors ........................................................................................................pag. 18

Clause 20 - Assignment of professional services ......................................................................................................................pag. 19

Clause 21 - Relations with the Public Administration and public contractors in general ......................................................pag. 19

Clause 22 - Relations with Institutions and Public Supervisory Authorities ..............................................................................pag. 20

Clause 23 - Contributions and sponsorships.............................................................................................................................pag. 21

Clause 24 – Grants and financing ............................................................................................................................................pag. 21

Clause 25 - Relations with political institutions, trade unions and associations ......................................................................pag. 21

Clause 26 – Relations with the mass media, research institutions, trade associations and similar Entities ...........................pag. 22

Clause 27 – Prevention of money laundering (Management of cash or assets) ..................................................................pag. 22

Clause 28 - Antitrust laws and gathering information on competitors ...................................................................................pag. 23

Clause 29 – Participation in gaming and betting.....................................................................................................................pag. 23

RESPONSIBLE GAMING ...................................................................................................................................................... pag. 24

Clause 30 - Protection of minors .................................................................................................................................................pag. 24

Clause 31 – Responsibility towards players................................................................................................................................pag. 24

PROTECTION OF ASSETS ................................................................................................................................................... pag. 25

Clause 32 - Protection of Industrial and Intellectual property rights .......................................................................................pag. 25

Clause 33 - Appropriate use of company assets ......................................................................................................................pag. 25

Clause 34 - Environmental protection .......................................................................................................................................pag. 26

CONFIDENTIAL INFORMATION AND “PRIVACY” POLICY .................................................................................................... pag. 27

Clause 35 - General principles ..................................................................................................................................................pag. 27

Clause 36 - Privacy Policy ...........................................................................................................................................................pag. 28

IMPLEMENTATION METHOD (IMPLEMENTATION, AMENDMENT AND VALIDITY .................................................................... pag. 29

Clause 37 - Supervisory Board ....................................................................................................................................................pag. 29

Clause 38 - Communications and training ...............................................................................................................................pag. 30

Clause 39 - Breach of the Code of Ethics .................................................................................................................................pag. 31

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INTRODUCTION

Novomatic Italia S.p.A. (hereinafter “Novomatic Italia” or the “Company”), was founded in 2007, and is a

subsidiary of the Austrian multinational company Novomatic AG, a world leader in the technological inno-

vation of slot machines and management of gaming halls. Novomatic Italia operates in Italy as a produ-

cer, rental agent and distributor of gaming machines, and through its subsidiaries, as owner and manager

of gaming halls and deals in the field of online gaming and sports bet collection.

Novomatic Italia together with its subsidiaries are the Novomatic Group Italia (hereinafter “Novomatic

Group Italy”).

Italian Legislative Decree 231 dated 8 June 2001, containing the “Regulations on the administrative respon-

sibility of corporate persons, companies and associations, including those without legal status, pursuant

to Article 11 of Italian Law 300 dated 29 September 2000”, introduced in the Italian legal system the admi-

nistrative responsibility of entities for a number of specifically listed crimes, committed in their interest or to

their advantage by persons who cover, both as to fact and law, functions of representation, administration

or management, or who are subject to the management and supervision of any of such entities. Article 6

of the above Decree sets forth however that the entity is not responsible for these crimes, if it can demon-

strate that it has adopted and efficiently implemented, before the crime was committed, “organisation and

management models to prevent crimes of the type committed”, which calls for the creation of a control

body, within the entity, whose task is to monitor the functioning and efficiency of, and compliance with, the

above models, and update the same.

An essential aspect of the organisational model adopted by entities pursuant to Italian Legislative Decree

231 of 2001 is the Code of Ethics, intended as the official document of the entity, approved by the top ma-

nagement of the same, containing the rights, duties, responsibilities and rules of conduct – of the entity

with respect to so-called “stakeholders” (employees, suppliers, customers, the Public Administration etc.),

over and above the provisions of applicable laws.

The Group today deals in many different, rapidly evolving, institutional, economic, political, social and

cultural contexts. All the activities of the Group shall therefore be performed in accordance with applica-

ble laws, according to the principles of fair competition, in order to create value through integrity, for its

customers, collaborators and the community as a whole. Creating value through integrity means acting

in an honest and correct manner, in accordance with the principles of good faith, to attain the legitimate

interests of its customers, employees, business and financial partners and the community with which the

Group interacts. All those who work for the Group, without distinction or exception, are committed to ensu-

ring compliance with these principles in their duties and responsibilities. The belief of acting in the interests

of the Group can in no way justify any action not complying with such principles.

For all the above reasons, and given the complexity of situations in which the Group deals, it is important to

clearly define the values that the Group recognises, accepts and shares as well as the responsibilities the

Group assumes within the company and towards others.

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Novomatic Italia accordingly recognises that adopting the Group Code of Ethics, complying with the

“Code of Conduct” of the Parent Company Novomatic AG, is an essential aspect of the function to control

and prevent the crimes that entities are called to implement, pursuant to Italian Legislative Decree 231 of

2001.

This document (hereinafter the “Code”), which is duly approved by the Board of Directors of Novomatic

Italia SpA as Holding of Novomatic Group Italy, has accordingly been adopted, on the understanding that

compliance with the same is considered to be an essential condition, not only to prevent the crimes set

forth by Italian Legislative Decree 231/2001, but also to ensure the proper functioning of Novomatic Group

Italy, protect its reliability, reputation and image and ensure greater customer satisfaction, all of which are

the essential cornerstones of the – current and future – success of Novomatic Group Italy. The Code, as

an authentic work tool and concrete point of reference for all stakeholders of the Group, sets forth princi-

ples that guarantee correctness, honesty, impartiality, equality, loyalty, legitimacy, professional integrity and

good faith, in the conduct, transactions and working method of the Group, its employees and all those

who collaborate to perform the activities of Novomatic Group Italy, and thus represent the conduct that

the same are called to implement and comply with pursuant to all and any applicable laws, the obliga-

tions set forth by collective bargaining and compliance with company procedures.

All employees of the Company and anyone who collaborates in the activities of Novomatic Italia Group

shall be familiar with Code, and shall contribute actively to ensure compliance with the same. To this end,

each Company of the Group, insofar as the same is responsible, undertakes to distribute the Code to the

maximum possible extent, also providing an appropriate training and awareness programme as to the

contents of the same.

The Companies of the Group (considered to be strategically important) will monitor compliance with the

rules of conduct set forth by the Code, even by designating a specific internal board (the“Supervisory

Board”).

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GENERAL PROVISIONS

Clause 1 - Scope of the Code of Ethics

1. The activities of the Company and its subsidiaries (“Group”) are inspired by full compliance of the

values and principles set forth by this Code, in the belief that integrity, honesty, correctness, loyal-

ty, impartiality and good faith are essential conditions for the lasting success of a company. The

company bodies, management, employees and collaborators of the Group, as well as anyone

else who acts on behalf of the Company (the “Addressees”), hereby undertake

- upon accepting the appointment or signing the employment or collaboration contract, and for

the entire period in which the same carry out activities for the Group or in the interests of the same

– to comply with the provisions of this Code.

2. The conduct of external collaborators of the Group (such as consultants and agents), and busi-

ness partners, shall comply with the provisions of this Code or, in any case, with the General prin-

ciples of the same.

Clause 2 - Addressees of the Code of Ethics

1. The “Addressees” as referred to herein are all the parties to whom the rules of this Code of Ethics

apply, and are intended as the Directors and members of the corporate bodies of all the compa-

nies of the Group, all the employees of the Companies of the Group and all those who, directly or

indirectly, stably or temporarily, establish relations with the Group, or in any case work to attain the

objectives thereof.

2. It is the managers of the Company who are first and foremost responsible for ensuring the sub-

stantiality of the values and principles of the Code, assuming responsibility thereof within the

company and towards others and strengthening Group trust, cohesion and spirit.

3. The employees of the Group, in due compliance with applicable laws and regulations, will con-

form their actions and conduct in accordance with the principles, aims and obligations set forth

by the Code.

4. In determining the company objectives, the members of the Board of Directors will base their de-

cisions on the principles set forth by the Code.

All and any actions, operations and negotiations, and in general, the conduct of the employees

of the Group in performing their work, shall be based on principles of maximum correctness in

terms of management, completeness and transparency of information, the formal and substan-

tive legitimacy, transparency and accuracy of accounts records, in accordance with applicable

laws and internal procedures.

Each employee shall provide professional skills appropriate to the responsibilities assigned thereto

and shall at all times protect the prestige and image of the Group.

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5. Each Addressee shall be familiar with the Code of Ethics, and actively contribute to implementing

the same, reporting any irregularities to the function to which it reports.

In order to ensure full compliance with the Code of Ethics, any employee who becomes aware of

situations that are an effective or potential breach of the Code of Ethics, shall immediately report

the same, to its manager and/or forward a report by e-mail to the Supervisory Board of its com-

pany as set forth by the Group procedure “Reports of breach of the Code and Model”.

Clause 3 – Distribution and implementation of the Code

1. The Group undertakes to:

a. ensure maximum distribution of this Code, including publication thereof on the Internet and/or

Intranet websites of the Company;

b. draft information, explanatory, training, awareness-raising documents on the contents of the

Code;

c. carry out periodic checks in order to monitor the level of compliance with the provisions of the

Code;

d. constantly update the Code according to economic, financial and business developments of the

activities of the Group, including any changes in its organisation or management, and the types

of breach ascertained pursuant to supervisory activities;

e. provide appropriate prevention tools, apply adequate penalties and promptly apply the same in

the case of ascertained breach of these provisions.

2. When dealing with third parties, Addressees shall:

a. promptly and adequately inform all parties who have dealings with the Group of the commit-

ments and obligations set forth by this Code;

b. ask suppliers, contractors, subcontractors, consultants, customers and anyone else who has con-

tractual dealings with the Group to comply with the provisions of this Code (which shall be an

integral part of the contracts) or, in any case, ensure that their conduct complies with the general

principles of the same;

c. report to the Supervisory Board any conduct not complying with the provisions of this Code.

Clause 4 – Principles on which company operations are based

1. In accordance with the mutual principles on which the Company is based, the primary aim of the

Group is to create added value for all categories of shareholders, by pursuing the best economic,

social and professional conditions, in its specific corporate activities.

To this end, in performing its activities, the Company undertakes to:

a. ensure and promote, within the Company, strict compliance with the laws and regulations in force

in every Country in which it operates, and with commonly accepted principles of transparency,

fairness and correctness in business practices;

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b. ensure and promote, within the Company, strict compliance with all organisation rules and pro-

cedures adopted by the Group, in particular those adopted for the prevention of crimes;

c. promote and request compliance with all the laws, regulations, principles, organisation rules and

procedures indicated by the above points even by their customers, employees and company

managers with whom common or coordinated activities are carried out, even temporarily;

d. refrain from any illegal conduct, or in any case any conduct not complying with the above prin-

ciples, in dealings with the Public Administration, public Supervisory Authorities, employees, custo-

mers, shareholders and competitors, in particular avoiding any discriminatory conduct;

e. guarantee compliance with principles of transparency and reliability with respect to its counter-

parties and the community in general, in compliance with the competitiveness of its work and the

competitiveness of the services offered;

f. guarantee and respect the professionalism and physical and moral integrity of its employees

and collaborators, as well as all-encompassing environmental and safety protection, above all as

regards the workplace;

g. avoid, prevent and repress any form of discrimination based on sex, age, sexual preferences, race,

language, nationality, social-economic conditions, philosophical and religious beliefs, political

and trade union opinions and disability.

2. In doing business, any breach of the above principles is detrimental to the relationship of confi-

dence between the Group and its stakeholders (“stakeholders” being intended as the categories

of persons, groups or institutions whose contribution is required to achieve the “mission” of the

Group or who have a common interest in attaining the same).

Attainment of the interests of the Group or obtaining an advantage for the same will at no time

justify any illegal conduct, or in any case, breach of applicable laws and the principles set forth

by this Code.

3. Addressees and Collaborators shall avoid situations whereby the parties involved have, or may

appear to have, a conflict of interests. Pursuant to this Code, a conflict of interest is intended as

any situation whereby the Addressees pursue a different interest to that of the Group - and, which

is thus, not consistent with the provisions of this Code – or perform activities which interfere with

the correct and transparent assumption of risks within the company, or personally take advanta-

ge of opportunities offered to the Group, or have dealings with parties who too have a conflict of

interests.

By way of example but not limited to, the following may constitute a conflict of interest:

a. an - obvious or secret - co-interest of employees or collaborators not having an employment rela-

tionship in the activities of suppliers, customers, competitors;

b. exploitation of position thereof to obtain interests in conflict with those of the Group;

c. use of information obtained in performing the working activities thereof to their own advantage

or that of third parties and in any case in conflict with the interests of the Group;

d. performing working activities of any kind (personal and intellectual services) for customers, sup-

pliers, competitors and/or third parties in conflict with the interests of the Group;

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e. conclusion, finalisation or commencement of negotiations and/or contracts involving the Group,

having as counterparties relatives or partners of the employees, or parties in any way referable to

the same.

4. Additional obligations for Managers of Company Units and Functions

The Managers of Company Units/Functions shall:

(i) through their conduct, be an example for their collaborators, guiding their collaborators to com-

ply with the Code and reference procedures;

(ii) ensure that collaborators understand that complying with the provisions of the Code, procedures

and safety regulations, are an essential part of the quality of their work;

(iii) carefully recruit, insofar as the same are responsible, internal and external collaborators, in order

to prevent the assignment of duties to persons who do not ensure compliance with the provisions

of the Code and procedures;

(iv) adopt immediate corrective measures when so required.

Clause 5 – Contractual value of the Code

The Code is an integral part of the employment relationship, pursuant to and by effect of Article 2104 of

the Civil Code et sequitur.

Compliance with the provisions set forth by the Code shall be considered as an essential part of the obli-

gations of Employees of Group Companies.

Breach of the provisions of the Code of Ethics may entail application of the measures set forth by clause

39 hereunder.

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Clause 6 - Books and records

1. Group accounting complies with generally accepted principles of the exactness, accuracy, com-

pleteness and transparency of the data recorded.

2. Addressees shall refrain from any active or omissive conduct, in direct or indirect breach of regula-

tory principles and/or internal procedures relevant to the preparation of accounting documents

and the external presentation thereof. In particular, Addressees shall collaborate to ensure that

all operations and transactions are promptly recorded in the accounts system of the company

in accordance with the principles set forth by law and applicable accounting standards, and, if

necessary, duly authorised and checked. Addressees shall also file and make available, for any

operation or transaction, appropriating supporting documents in order to ensure:

a. accurate entry in the accounts;

b. immediate identification of the characteristics and underlying reasons;

c. easy formal and chronological reconstruction thereof;

d. verification of the decision-making, authorisation and implementation processes, in terms of legi-

timacy, consistency and adequacy, and identification of the different levels of responsibility.

3. Addressees who become aware of omissions, falsification or negligence in accounting entries or

supporting documents, shall immediately report the same to their manager and the Supervisory

Board.

4. The Group promotes training and updating programmes in order to inform Addressees of the

rules (laws or regulations, internal regulations, provisions of trade associations) relevant to the

preparation and management of accounts documents.

Clause 7 - Internal controls

1. The Group promotes a control-oriented approach at all levels.

In particular, Novomatic Group Italy considers that the Internal Control System must encourage

the attainment of company goals and thus, aim at improving the effectiveness and efficiency of

the production and management processes. A positive attitude to controls contributes significan-

tly to improving company efficiency.

TRANSPARENCY OF ACCOUNTS REPORTING AND INTERNAL CONTROLS

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2. Internal controls are intended as the means adopted by the Company to address, manage and

check company activities in order to ensure compliance with applicable laws and company pro-

cedures, protect company assets, efficiently manage activities and provide accurate, transparent

and complete accounting and financial data. Each operation and transaction shall be correctly

recorded, authorised, auditable, legitimate, consistent and accurate.

3. Each level of the organisation structure shall contribute to implementing an effective and efficient

control system. To this end, all employees of the Group, within the limits of their functions and du-

ties, are responsible for correctly implementing the control system.

4. The Internal Audit of the Group, the independent auditors and control Bodies appointed by the

Companies, have full access to all data, documents and information required to perform their

activities.

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CONDUCT OF THE TOP MANAGEMENT

Clause 8 - General principles

1. The members of the Board of Directors, auditors, senior managers, and department managers

of the Group shall comply with the provisions of this Code and work according to values of

honesty, loyalty, correctness and integrity, consciously sharing the mission of the Group.

2. The members of the Board of Directors and top management are responsibility for ensuring

the substantiality of the principles set forth by this Code, strengthening the trust, cohesion and

mutual spirit by which company operations are inspired. To this end, in determining company

objectives, the Board of Directors bases its decisions on the values set forth by the Code.

Clause 9 - Conflicts of interest

1. The members of the Board of Directors, auditors, department managers, and senior managers

of the Group shall refrain from any activity that may be considered, even potentially, to be in

conflict with the interests of the Group. In accordance with the principle of full transparency to

“stakeholders”, each of the above shall evaluate the above situations in the strictest possible

manner.

2. In the case of even only potential internal and external conflicts of interest, with respect to

company activities, the person concerned shall refrain from such conflicting conduct imme-

diately reporting the same to the Supervisory Board, who is responsible for evaluating the

existence or otherwise, on a case by case basis, of situations of incompatibility or detrimental

situations.

3. The members of the Board of Directors, auditors, department managers, and senior managers

of the Group must comply with principles of loyalty, correctness and transparency when clai-

ming reimbursement of expenses; to this end, they shall be familiar and comply with applica-

ble internal procedures of the Group, ensuring, in particular, that each reimbursement claim is

appropriately documented or documentable.

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Clause 10 - General principles

1. The Group recognises the central role of human resources in the belief that the most important

factor of success of any company is the contribution of the persons who work for the same, who

are asked to offer professionalism, dedication, loyalty, honesty and a spirit of collaboration. For this

reason, Novomatic Group Italy protects the value of people.

To this end, the Group is committed to ensuring working conditions that protect the psychological-

physical integrity of workers and respect their moral personality, avoiding any kind of discrimina-

tion, illegal coercion or undue distress.

2. The Group applies principles of merit, expertise and professionalism when making decisions re-

lating to the employment relationship with their employees and collaborators. Any discrimination

in the recruitment, engagement, training, management development and salaries of personnel,

based on sex, age, sexual preferences, race, language, nationality, social-economic conditions,

philosophical and religious beliefs, political and trade union opinions or disability is strictly prohi-

bited, including any form of nepotism and favouritism.

3. The Management of the Group ensures that the behaviour of all department managers, emplo-

yees and collaborators, insofar as the same are responsible, complies with the above principles

and implements the same.

4. For more information as regards the operational procedures of personnel please see the “Com-

pany Regulations” and other specific procedures.

Clause 11 – Recruitment of personnel

1. Personnel is recruited according to company requirements, ensuring that the profile of the person

concerned corresponds to the job profile requested, in accordance with the principle of equal

opportunities for everyone.

2. The information requested during the recruitment process is strictly related to ascertaining the

professional and psychological-aptitude profile requested, while respecting the privacy of the

candidate, and the personal opinions thereof.

3. The personnel of the Group is taken on with a regular employment contract in compliance with

applicable labour laws and laws on the employment of foreign citizens. No form of employment

that does not comply with applicable laws and national collective labour agreements is allowed.

PERSONNEL POLICIES

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Clause 12 – Management of Personnel

1. Roles and/or duties are defined according to the expertise and ability of individuals, according

to the specific requirements of the Group. Compatibly with the criteria of the general efficiency of

work, the Group promotes flexible working times to facilitate the management of pregnancy and,

more generally, child care.

2. Within the personnel management and development processes, decisions made from time to

time (for example, promotions, transfer or result-based incentives) are based on the effective cor-

respondence of the profiles held by collaborators and planned or reasonable goals, including

merit.

3. Department managers shall use and maximise all the professional skills in the company, so as to

encourage the development and growth of personnel, through appropriate tools (job rotation,

tutoring by expert personnel, experiences to take on roles of greater responsibility etc.). All per-

sonnel are fully involved in performing work, by allowing the same to participate in discussions

and decisions relevant to the attainment of company goals. Personnel should participate in such

discussions with a spirit of collaboration.

4. Addressees are expressly prohibited from implementing any form of abuse of their position of

authority, consisting in requesting, and taking for granted that this is due to someone in a higher

management level, services and personal favours, and in general behaving in any way that is

detrimental to the dignity, professionalism and autonomy of the subordinate employee, or that in

any way constitutes breach of this Code of Ethics.

Clause 13 – Environment, Safety and Health of workers

1. The Group encourages and consolidates a culture of safety and health of workers at the workpla-

ce, ensuring that workers are aware of risks and encouraging responsible behaviour on the part

of all personnel. With respect to its employees and collaborators the Group complies in full with

the provisions set forth by Italian Legislative Decree 81/08 and any other laws that may be appli-

cable from time to time according to the type and location of the activities actually performed.

2. To this end, the Group – moreover - undertakes to implement technical and organisational inter-

ventions, concerning:

a. a continuous analysis of the risks and criticalities of processes and resources requiring protection;

b. use of the most appropriate technologies to prevent the onset of risks for the safety and health of

workers;

c. the control and updating of working methods;

d. the adaptation of work to people, above all as regards the concept of the workplaces, choice of

tools and equipment, work and production methods in order to attenuate monotonous types of

work and the effect thereof on health;

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e. prevention planning, in order to implement a coherent system, which includes work techniques

and organisation, working conditions, social relations, the impact of workplace factors;

f. the contribution of training and communications.

3. Within the scope of their duties, addressees participate in the risk prevention and workplace he-

alth and safety process, both with respect to themselves and with respect to their colleagues and

third parties.

4. The Group is committed to developing training (and information) programmes, structured diffe-

rent according to addressees.

5. Novomatic Italia respects the environment as a resource that shall be protected, for the benefit of

the community and future generations. Novomatic Italia accordingly adopts all the most appro-

priate measures to safeguard the environment, in accordance with applicable laws, promoting

and programming activities in accordance with this goal and promoting awareness-raising initia-

tives.

Clause 14 - Right to personal safety

1. The Group is committed to protecting the moral integrity of personnel, guaranteeing to the same

the right to working conditions, which respect the dignity of people. To this end, the Group will not

tolerate any psychological abuse or discriminating behaviour or attitude or conduct that is detri-

mental to the person, or the beliefs and preferences thereof.

2. The Group does not tolerate sexual harassment, nor any conduct or conversation that may upset

the sensitivity of people. Sexual harassment is intended as any of the following:

a. subjecting decisions relevant to the working life of the addressee to the acceptance of unwelco-

me sexual favours;

b. proposals for private personal relations despite the fact that these are expressly or reasonably

unwelcome, and that – considering the specific situation – disturb the peace of mind of the ad-

dressee, with objective implications on the working ability thereof.

3. Addressees who consider that they have been victims of harassment or have suffered any form of

discrimination for reasons related to sex, race, health, nationality, political opinions and religious

beliefs, may report this to the Supervisory Board, who will evaluate the circumstances in order to

adopt any necessary measures together with the company management.

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Clause 15 – Duties of personnel

1. Employees and collaborators of the Group shall:

a. ensure that their work is based on principles of professionalism, transparency correctness and

honesty, and shall contribute, together with their colleagues, superiors and collaborators, to at-

taining the mission of the Group, in compliance with legal, statutory and contractual obligations

and in particular with the provisions set forth by this Code;

b. prepare documents in a clear and comprehensive manner, allowing the same to be checked by

persons authorised to do so;

c. behave at all times in a loyal, correct and transparent manner when claiming reimbursement of

expenses; to this end, the same shall be familiar and comply with the applicable internal proce-

dures of the Group, ensuring above all that all claims for the reimbursement of expenses are fully

documented and documentable;

d. not exploit the name and reputation of the Group for private purposes, nor exploit their position

within the Group for personal reasons.

2. Employees and collaborators of the Group shall not carry out any activity that may be in conflict,

even potentially, with the interests of the Group nor personally take advantage of business oppor-

tunities of which they may become aware in performing their duties.

In the case of any conflict of interests, even potentially, as defined by clause 4, paragraph 3 above,

the employees and collaborators of the Group shall not implement the conflicting conduct and

shall immediately report the same to their superior and to the Supervisory Board, who shall be re-

sponsible for evaluating the existence or otherwise of any incompatible or detrimental situations,

on a case by case basis.

a. A potential conflict of interests exists in all cases when a relative covers a higher management

position or works in the same or a higher department. Relatives by marriage will only taken on

if the decision by one of the companies of the Group is based on objective elements such as

skills, professional qualifications, ability and experience, following the recruitment procedure, and

if there is no first line reporting between the employee and its superior. Any conflict of interests de-

termined as above shall be reported to the Supervisory Board. This rule is not applied in the case

of short-term engagements (internships etc.).

3. Each employee and collaborator of the Group shall diligently exert its best efforts to protect the

assets of the company, through responsible behaviour complying with the operational procedu-

res and company instructions governing the use thereof. In particular, employees and collabora-

tors shall:

a. use the assets allocated to the same carefully and thriftily;

b. avoid any improper use of company assets that may damage or reduce the efficiency thereof or

which in any case is in conflict with the interests of the Group.

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4. As regards computer applications, all employees and collaborators of the Group shall use the

hardware and software placed at the disposal thereof exclusively for purposes related to their

duties. In particular, employees and collaborators shall:

a. strictly apply the procedures set forth by the company safety policies, so as to avoid any damage

to the functions and protection of the computer systems;

b. not unlawfully duplicate the programmes installed on computers;

c. not forward threatening or offensive e-mail messages, use low-level language, express inappro-

priate comments that may be offensive to people or the company image;

d. not browse websites whose contents are prohibited by law, in any case complying with the e-mail

and internet Regulations.

5. The Group strictly prohibits – both Addressees of this Code and Collaborators – to alter the fun-

ctioning of information technology and computer systems in any way and/or to tamper with the

data stored in the same in order to obtain an unfair profit thus damaging public administrations.

6. Without prejudice to the fact that no smoking is allowed in areas where a no smoking sign is

displayed, in situations where the workplace is shared, the Group takes into particular account

those who are disturbed by smoking and wish to be protected from “second-hand smoking” at

the workplace.

7. Employees of the Group shall dress in a professional manner, when dealing with customers, sup-

pliers and/or the public, in carrying out their work.

- pag. 17 -

Clause 16 - General principles

1. The individual and joint behaviour of all Addressees in carrying out any operation to attain the

goals of the individual companies of the Group – should always comply with company policies

and the policies defined by the Group, effectively resulting in collaboration, social responsibility

and compliance with national and international laws.

2. The business dealings of the Group are based on principles of loyalty, transparency, efficiency,

openness to markets, the prevention of money laundering and protection of industrial and intel-

lectual property rights.

3. Novomatic Group Italy is committed to honesty in its business dealings; persons who act in the

name and/or behalf of the companies of the Group cannot propose, suggest, offer or give mo-

ney, donations or other benefits (for example, suggest and/or give a job or, in any case, a colla-

boration and/or paid assignment) to a person directly invested with decision-making authority or

third party, in order to obtain undue advantages, above all in dealings with the Public Administra-

tion.

Similarly, on the contrary, cash, donations or other benefits (for example, offers of a job or collabo-

ration and/or appointment) cannot be requested or accepted, against a fee which is not merely

symbolic, for personal benefit or the benefit of a third party, for a specific action or any form of

counter-service.

Clause 17 – Gifts and other benefits

1. In dealings with Customers, Suppliers, Addressees and third parties in general, no gifts, offers of

cash or benefits of any kind may be given or made (for example services, works contracts or trips)

in a personal capacity in order to obtain real or apparent undue advantages of any kind (e.g.

promises of economic advantages, favours, recommendations, promises of job offers or offers

exceeding reasonable courtesy), that may be interpreted as exceeding standard commercial

practices or courtesy. The Group refrains from any practices not permitted by law, commercial

practices or the codes of ethics, if known, of the companies or entities which it has dealings,

adopting a policy of Zero Tolerance towards any form of corruption. In any case, offers of gifts

by the Group – other than gifts of moderate or symbolic value – shall be approved by the Line

manager of the function involved and communicated to the Supervisory Board.

BUSINESS ETHICS

- pag. 18 -

2. Addressees who, in performing their duties, receive, even during holiday periods, gifts, donations

and other benefits not having a moderate or symbolic value and exceeding normal courtesy

relations, shall, in accordance with the procedures established, immediately inform the Line ma-

nager of the function involved and the Supervisory Board, who will evaluate the appropriateness

of the same, and return the same if necessary, informing the sender of the policy adopted by the

Group as regards gifts, donations and benefits.

Clause 18 – Relations with customers and private contractors

1. Novomatic Group Italy pursues its sales objectives on national and international markets by of-

fering high quality legal gaming products at competitive terms and in compliance with antitrust

laws. In dealing with Customers and as set forth by internal procedures, Addressees shall ensure

maximum Customer satisfaction, in particular, by providing accurate and full information on the

products supplied under the Novomatic Italia (or Novomatic AG and Austrian Gaming Industries)

brand, so as to ensure informed choices but also to create the conditions for customer retention

based on correctness, honesty, efficiency and professionalism.

2. Collaborators may not offer benefits, fees or incentives in breach of the law and commercial

Group policies.

3. Although the Group does not preclude any customer or category of customers, it does not deal,

either directly or indirectly, with persons who are known to belong or are suspected of belonging

to criminal organisations or in any case who operate illegally, such as, persons having ties with

money laundering, drug trafficking or usury.

Clause 19 – Relations with suppliers and subcontractors

1. The Group establishes relations with its suppliers and subcontractors in compliance with applica-

ble laws and the principles of this Code, according to the best professional standards, the best

ethical practices, health and safety protection and respect of the environment, based on princi-

ples of correctness, efficiency and reliability.

2. The procedures for the selection of the suppliers and subcontractors of the Group – based on

objective information – in particular take into account, economical convenience, technical ca-

pacity, reliability, quality of materials/services, compliance of the supplier with the quality proce-

dures adopted by the Company and the credentials of its contractors.

The relevant functions shall in any case ensure – wherever possible – equal opportunities to sup-

pliers who have the required requisites. In its supplier selection procedures, the Group implements

periodic monitoring mechanisms to ensure that suppliers continue to have the above required

requisites.

- pag. 19 -

3. In dealings with suppliers and subcontractors, Addressees may not accept fees, gifts or prefe-

rential treatment that do not comply with the conditions set forth by the above par. 2 of clause

16. Addressees shall in any case inform the function manager and the Supervisory Board if such

offers are received. Similarly, gifts or preferential treatment not complying with the provisions set

forth by clause 17 may not be offered or made.

4. The Group ensures maximum transparency and efficiency of the purchasing process from its sup-

pliers, by separating the roles of the unit who requests the supply and the unit who stipulates the

contract together with appropriate traceability of choices.

5. Contracts signed with Suppliers shall always be based on very clear dealings, avoiding wherever

possible contractual obligations that imply any form of dependency on the Supplier.

Clause 20 - Assignment of professional services

1. In assigning professional services, the Group adopts assignment principles based on affordability,

transparency and correctness, and also evaluates the moral and professional integrity of poten-

tial collaborators.

2. Fees and/or sums paid for any reason whatsoever to third parties to whom professional services

have been assigned should in any case be traceable and proportionate to the services carried

out, taking into account market conditions.

3. In assigning professional services, Addressees may not accept fees, gifts or preferential treatment

in breach of the provisions set forth by par. 1 of clause 17, and should inform the function ma-

nager and the Supervisory Board if such offers are received. Likewise, no gifts or preferential tre-

atment in breach of the conditions set forth by clause 17, may be offered or given to the above.

Clause 21 – Relations with the Public Administration and public contractors in general

1. Relations of the Group with the Public Administration, public officials or persons responsible for a

public service shall strictly comply with applicable laws and regulations and should not prejudice

the integrity and reputation of the Group in any way.

2. Only designated company functions and authorised personnel may accept commitments and

manage relations, of any kind, with the Public Administration, public officials or persons responsi-

ble for a public service.

Such functions and personnel shall in any case diligently file all the documents relevant to proce-

dures pursuant to which the Group came into contact with the Public Administration.

3. Without prejudice to the provisions of par. 2, clause 19, in the case of business negotiations or

dealings, including those of a non-commercial nature, between the Group and public entities,

- pag. 20 -

Addressees shall not:

a. offer, even through a third party, job or commercial opportunities to the public official involved

in the negotiation or relationship, to relatives thereof or to anyone in any way associated to the

same;

b. offer to the above officials, gifts, donations or benefits, even through third parties, other than acts

of commercial courtesy of moderate value;

c. attempt to extort confidential information from the public official, even through a third party;

d. be responsible for actions or practices whose intention is to improperly influence the decisions

of the counterparty, including those of officials who deal with or make decisions on behalf of the

Public Administration.

4. Acts of commercial courtesy, such as gifts, donations in kind or any other benefit – not having a

moderate or symbolic value – are permitted only if the same are made in accordance with the

provisions set forth by clause 17.

Clause 22 – Relations with Institutions and Public Supervisory Authorities

1. The Addressees undertake to comply in full with the directives of Institutions or Authorities calling

for compliance with applicable laws in fields related to the respective areas of activity.

2. The Group shall ensure that, in applications to Institutions and/or Public Supervisory Authorities,

no requests or claims are submitted containing untrue declarations with the scope of obtaining

public funds, contributions or subsidized loans, or to obtain concessions, authorisations, licences

or other administrative acts.

Likewise, when participating in public tenders Addressees and Collaborators will act in full com-

pliance with applicable laws and according to principles of correct commercial practice, and in

particular, shall not induce administrations to act in favour of the Group.

Addressees undertake to ensure that public funds, contributions or subsidized grants granted to

the Group are used to perform the activities or implement the initiatives for which the same are

granted.

3. Addressees undertake to comply with all and any requests made by the above Institutions or Au-

thorities within their respective supervisory functions, offering – if requested – their full collaboration

to the same.

4. Without prejudice to the provisions set forth by this Code relevant to Conflicts of interest and prin-

ciples of behaviour in relations with the Authorities set forth by clause 21 above.

5. Former employees of the Public Administration, who in exercising their duties have had dealings

with the Group, or the relatives and/or relatives by marriage thereof, may be employed by the

Group only in strict compliance with the standard procedures of the Company for the Recruit-

ment of personnel. Other working relationships with former employees of the Public Administra-

tion, or with relatives or relatives by marriage thereof, shall also be handled in strict compliance

with company procedures.

- pag. 21 -

Clause 23 - Contributions and sponsorships

1. Without prejudice to the provisions of clause 21 above, the Group may accept requests for public

contributions or sponsorships from associations of high cultural, beneficial or recreational value

having regular by-laws and deed of incorporation, at a national level or in any case involving a

high number of citizens above all in the territory. All sponsorships and/or donations shall be based

on principles of transparency, in other words both the identity of the beneficiary and the activities

sponsored should be recognised and documented.

2. Sponsorship activities – for social, environmental, sports and artistic initiatives, shall involve events

that guarantee quality and reliability.

Clause 24 – Grants and financing

1. Contributions, subsidies or financing obtained from the European Union, the State, other States

where the Group is present or other Public Entities, shall be used for the purpose for which the

same are requested or granted, even if for moderate a sum and/or value.

Clause 25 - Relations with political institutions, trade unions and associations

1. The Group does not make direct or indirect contributions of any kind, to political and trade union

parties, movements, committees and organisations, or to the representatives and candidates the-

reof, other than as permitted by applicable laws and in full compliance with the principle of tran-

sparency.

2. Employees recognise and acknowledge that any form of involvement in political activities is strictly

personal, and shall be carried out in their own free time, at their expense and in full compliance

with applicable laws, and that such activities are NOT carried out as collaborator of the Group.

Corporate databases, data and archives or any other property of the companies of the Group

shall not be used for purposes of political propaganda. Finally, funds of the Group may not be

donated to political parties or politicians.

3. Moreover, the Group does not make contributions to organisations with which there may be a

conflict of interests (such as trade unions, consumer associations). Some form of collaboration

may be possible when: the purpose thereof is associated to the mission of the Group or projects

of public interest; the allocation of resources is clear and traceable; the designated company

functions have expressly authorised the same.

4. The Group liaises with all political forces in a transparent manner, voicing its position on topics

and themes of interest.

- pag. 22 -

5. Specific positions of the Group may be voiced to political forces and/or associations only with the

prior consent of the Senior Management and the designated functions.

Clause 26 – Relations with the mass media, research institutions, trade associations and similar Entities

1. Any information, which is made public, shall be true and transparent.

2. The Group shall present itself in a true and uniform manner in communications with the mass

media, research institutions, trade associations and any other equivalent entities. Relations with

the mass media, research institutes, trade associations and other entities equivalent to the same

are reserved only to the designated corporate functions and responsibilities pursuant to specific

delegations and are agreed in advance with the Board of Directors and Managing Director re-

sponsible for Public Relations, in coordination with the Communications Manager of the Group.

No other employees of the Company, with exception of those specifically designated pursuant

to the preceding paragraph, may release information to representatives of the mass media, re-

search institutes, trade associations and other entities equivalent to the same, nor undertake to

release such information, without the prior authorisation of the BoD.

3. Employees of the Group shall not offer payments, gifts or other benefits, for any reason whatsoever,

with the intention of influencing the professional activities of the officials of the entities, companies

or associations indicated by the above paragraph, or that may in any case be reasonably inter-

preted as such.

4. In the case of participation in congresses, conferences and seminars, drafting articles, texts and

publications in general, or in the case of participation in public interventions, all and information

relating to the activities, results, viewpoints and strategies of the Group, may only be disclosed,

unless the same are already in the public domain, if such information has been communicated

to and authorised by a superior and the BoD.

Clause 27 – Prevention of money laundering (Management of cash or assets)

1. The Company shall do business only with customers and suppliers having a reliable reputation,

who engage in legal business activities and whose earnings are obtained from legal sources.

2. Each company of the Group shall implement appropriate measures to guarantee that no forms

of payment, which may constitute money laundering, are accepted.

3. The Group is committed to complying in full with applicable anti-money laundering laws.

The integrity and reputation of the Company may be seriously damages by failure to identify money

laundering transactions.

- pag. 23 -

Clause 28 - Antitrust laws and gathering information on competitors

1. The Group competes on the market with integrity and complies with laws on free competition and

the antitrust laws in force.

2. The Companies of the Group shall not enter formal or informal agreements, whose scope is to

limit or narrow competition, nor exchange information as regards the marketing and sale of pro-

ducts and services. Illegal agreements are intended and include those whose scope is to deter-

mine or exercise control on prices, the allocation of products, markets or territories, customers or

suppliers, determine the sales prices of a product or condition the sale of specific products or the

stipulation of a purchase contract for the products of another company. The aim of the Group to

offer competitive services and products in terms of quality, reliability and price shall be attained

without prejudice to its business integrity.

3. Only appropriate and legitimate means shall be used to gather marketing and commercial infor-

mation on competitors. The Group does not exert undue pressure and does not attempt to obtain

confidential information held by current or former employees of competitor companies.

Clause 29 – Participation in gaming and betting

1. The members of the corporate bodies and employees of the Company shall not participate, ei-

ther directly or indirectly or through relatives and family members, in the games managed by the

companies of the Group. In particular employees, members of the corporate bodies and consul-

tants of the Group shall not participate in, claim or obtain any benefit from, either directly or throu-

gh third parties, activities associated to online gaming and slot machines, gaming machines or

video lottery machines (hereinafter “machine”) if the machine has been supplied by the Group

or the machine is linked to a centralised control system or system of the Group, regardless of the

company that supplies the machine.

2. Employees, members of the corporate bodies and consultants of the Company shall inform their

direct family members and relatives of the possible restrictions imposed by this Code of Ethics.

- pag. 24 -

Clause 30 – Protection of minors

1. The Company does not allow access to gaming to minors under the age of 18. To this end, the

Company has provided instructions to the sales network not to accept gaming requests from

minors under the age of 18.

Clause 31 – Responsibility towards players

1. The Company places particular importance on customers who choose the halls and gaming

methods offered by Novomatic Group Italy, informing users and customers as set forth by law and

the Administration of the State Monopolies on the probability of winning, the risks of gaming and

applicable prohibitions.

2. Offering SAFE GAMING is one of our priorities, and to this end all personnel in contact with cu-

stomers and players are trained to offer support to those who do not consider gaming merely a

recreational activity.

RESPONSIBLE GAMING

- pag. 25 -

Clause 32 – Protection of Industrial and Intellectual property rights

1. In implementing the principle of compliance with applicable laws, the Group guarantees com-

pliance with internal regulations, community and international laws on the protection of industrial

and intellectual property rights.

2. Addressees shall encourage the correct use, for any purpose and in any form, of brands, distin-

guishing marks and creative intellectual works, including computer programmes and databanks,

to protect property rights and the author’s moral rights. Any counterfeiting, alteration, duplication,

reproduction or distribution of third party works, in any form and without rights thereto, is strictly

prohibited.

In performing their duties, employees and collaborators shall in particular refrain from:

• any conduct that may constitute misappropriation of industrial property rights, alteration or

counterfeiting of the distinguishing marks of national or foreign industrial products, or patents,

designs or industrial models, and shall refrain from importing, marketing or in any case using or

placing on the market industrial products bearing counterfeit or altered distinguishing marks or

produced pursuant to the misappropriation of industrial property rights;

• usingintellectualworks(oranypartthereof)protectedbythecopyrightlawinanillegaland/or

improper manner, in their own interest or that of the company or third parties.

Clause 33 – Appropriate use of company assets

1. Each Addressee is responsible for protecting the resources allocated to the same and shall

promptly inform the designated functions of any threats to, or events that may damage, the

Group.

In particular, each Addressee shall:

• exertitsbesteffortstoprotectcompanyassets,bybehavinginaresponsiblemannerandcom-

plying with the operative procedures applicable to use of the same;

• avoidanyimproperuseofthecompanyassetsthatmaydamageorreduceefficiency,orwhich

is in any case in conflict the interests of the company;

• obtainallandanyauthorisationthatmayberequiredornecessaryforuseofsuchassetsoutside

the company.

2. Our increasing dependency on information technology means that it is necessary to ensure the

availability, safety, integrity and full efficiency of this particular category of assets.

RESPONSIBLE GAMING PROTECTION OF ASSETS

- pag. 26 -

All Addressees shall:

• strictlycomplywiththeprovisionsofthecompanysafetypolicies,soasnottodamagetheefficiency

and security of information technology systems;

• notdownloadonthecompanysystemsanysoftwarethathasbeenborrowedorhasnotbeenau-

thorised and shall never at any time make unauthorised copies of licensed software for personal

and company use or for third parties.

3. Even unintentional use of these assets for any purposes not relating to company business, may cau-

se serious damages (economic, image and competitiveness etc.) to the Group, with the additional

aggravating circumstance that such improper use may entail the application of criminal and admi-

nistrative penalties against the Group in the case of offences, making it necessary to take disciplina-

ry measures against Addressees.

Clause 34 – Environmental protection

1. The environment is a primary asset that the Group is committed to protecting. In planning its acti-

vities therefore, the Company tries at all times to find a balance between economic initiatives and

essential environmental requirements, in consideration of the rights of future generations.

2. The Group is accordingly committed to improving the impact of its activities on the environment and

the landscape, and preventing risks to populations and the environment, not only in accordance

with applicable laws, but also taking into account developments in scientific research and best

practices.

- pag. 27 -

Clause 35 - General principles

1. The Group is committed to protecting the confidentiality of all and any personal details of

which it may become aware (for example, information relating to employees and third parties

generated or acquired internally or in business relations) and shall avoid any improper use of

such information or undue distribution of the same.

Such information is in any case distributed internally only to persons who need to know or use

the same, who shall in turn distribute the information only as appropriate and in appropriate

places.

2. The Group implements and constantly updates specific procedures to protect such personal

details. In particular, the Group is committed to:

a. ensuring the correct separation of roles and responsibilities within the functions designated to

process personal details;

b. classifying information according to different levels of confidentiality and adopting all the most

appropriate measures for each stage of processing;

c. entering into specific agreements (including confidentiality agreements) with parties not be-

longing to the company involved in the processing of personal details, or who may in any way

become aware of confidential information.

3. Addressees shall reserve the necessary confidentiality, as required by particular circumstan-

ces, to any information of which it may become aware in performing its duties, above all to

protect the technical, financial, legal, administrative, management and commercial knowhow

of the Group. In Particular, Addressees shall:

a. obtain and process only the information and data necessary for the scope of the function to

which it belongs and directly in relation to the same;

b. obtain and process information and data only within the limits set forth by the specific proce-

dures adopted by the Group;

c. store data and information in such a way as to prevent unauthorised persons from becoming

aware of the same;

d. disclose data and information in according with specific procedures or with the express appro-

val of superiors and, in any case, after ensuring that the data may be disclosed in the specific

circumstances;

e. ensure that no absolute or relative restrictions apply to the disclosure of data and information

referring to third parties associated to the Group by any type of relationship, and if necessary,

shall obtain the consent thereof.

CONFIDENTIAL INFORMATION AND “PRIVACY POLICY”

- pag. 28 -

Clause 36 – Privacy Policy

1. The Group undertakes to protect, in full compliance with the provisions of Italian Legislative Decree

196/2003, and regulatory explanations (hereinafter the, “Privacy Law”), all and any personal details

acquired, stored and processed pursuant to its activities and business relations in order to avoid any

illegal and improper processing of such information. In particular, the Group adopts specific stan-

dards in order to:

a. communicate the information requested to the persons to whom the details refer including the data

processing and storage methods;

b. prohibit all and any processing, and/or disclosure and/or dissemination of personal details without

the prior consent of the person concerned, other than in the cases set forth by law;

c. adopt safety measures to prevent the loss and destruction of data, unauthorised processing or the

theft of personal details stored by the Group;

d. define rules to guarantee that the persons concerned may exercise the rights set forth by law.

2. No enquiries may in any case be made as regards the ideas, preferences, personal tastes and, in

general, the private life of employees and collaborators.

- pag. 29 -

This Code of Ethics is adopted pursuant to resolution of the Board of Directors of Novomatic Italia SpA

dated 12 September 2014.Any updates, amendments or revisions to this Code of Ethics shall be approved by the Board of Direc-

tors of Novomatic Italia SpA.

Clause 37 - Supervisory Board

1. The body designated to implement this Code is the Supervisory Board of the individual Com-

panies of the Group, created pursuant and subject to the “Organisation, management and

control model”, adopted by the Board of Directors of the individual Companies of the Group.

In addition to the functions allocated to the same by the above Model, the Supervisory Board

has the following duties:

a. ensures the application of, and compliance with, the Code of Ethics;

b. encourages the dissemination of increasingly higher principles of ethical conduct in the Group

by analysing and evaluating the risk control processes [ethical];

c. encourages initiatives to increase awareness and understanding of the Code (in particular:

guarantees the development of ethical training and communications activities; analyses pro-

posals to review operating procedures and company directives which have a significant im-

pact on company ethics), by preparing specific training/information programmes;

d. receives and analyses any reports of breach of this Code, while ensuring the necessary confi-

dentiality;

e. makes the necessary decisions as regards any cases of breach of the provisions set forth by

the Code;

f. expresses opinions as regards revisions of operating procedures, to ensure that these are con-

sistent with the Code;

g. informs the Board of Directors, and the Board of Auditors of the Company if it is necessary to

review the rules of the Code;

h. participates in the drafting of all operating procedures to reduce the risks of breach of this

Code, endorsing the constant updating of the same in the appropriate measure;

i. ensures the application of and compliance with the provisions of this Code, even by the com-

panies of the Group, through a reporting system by the management bodies of such compa-

nies, informing the competent bodies if it is necessary to review the rules of the Code of Ethics.

2. In performing these activities, the Supervisory Board will be supported by all the company fun-

ctions involved and will have full access to all and any documents required to perform such

activities.

IMPLEMENTATION METHOD (IMPLEMENTATION, AMENDMENT AND VALIDITY

- pag. 30 -

Clause 38 – Communications and training

1. Addressees will be informed of this Code of Ethics and the attachments thereof through specific

communications activities.

2. In order to ensure that the Code of Ethics is correctly understood by all Addressees. the “Internal Au-

dit” function will draft and prepare, according to the instructions of the Supervisory Board, an annual

training plan in order to ensure that the main contents of the Code of Ethics are known, differentia-

ting the same according to the role and responsibilities of addressees.

Clause 39 – Breach of the Code of Ethics

1. Compliance with the rules of the Code of Ethics is an essential part of the contractual obligations of

the employees of the Company, pursuant to and by effect of Articles 2104 and 2106 of the Civil Code.

2. Breach of the above rules constitutes breach of the obligations deriving from the employment or

collaboration contract, with the consequences set forth by law or the contract. In particular, as re-

gards employees, this Code is specifically referred to by the Disciplinary Code of the Company as the

source of provisions for the execution and regulation of work given by the entrepreneur pursuant to

the above Article 2104 of the Civil Code.

3. The Company shall apply disciplinary measures, in a coherent, impartial, uniform and proportionate

manner with respect to the breach in question, and in any case in accordance with the limits set

forth by law and the collective bargaining contract of the industry, and internal social Regulations.

4. In contractual relations between the Company and all other parties, compliance with the Code shall

be an integral part of the obligations assumed with respect to the Group. To this end, the existence

of the Code shall be expressly mentioned in each contract and a copy of the same will be given to

all parties who have commercial relations with the Group.

5. Breach of the rules set forth by this Code may therefore constitute breach of contractual obligations,

with all the consequences set forth by law, and may entail termination of the contract or appoin-

tment and compensation of damages, if any.

- pag. 31 -

CONTACTS

For further information as regards the Organisation Model or to discuss specific pro-

blems, please do not hesitate to write to:

Email: odv@novomatic.it

For more information you may also contact the Group contact persons of Novomatic AG: csr@novomatic.com

as regards Corporate Social Responsibility matters dataprivacy@novomatic.com as regards Data Privacy

matters antimoneylaundering@novomatic.com as regards Anti-money laundering matters

communications@novomatic.com for the policy on relations with the media and disclosure of information

ipenforcement@novomatic.com to report parasitic copying of the Novomatic logo compliance@novomatic.com