Organizational model pursuant to legislative decree no. 231/2001

Valeo S.p.A. approved and adopted a 231 Model designed to prevent unlawful acts referred to in the corresponding Decree and, consequently, shield the Company from administrative liability.

The Model includes a detailed analysis of the Company’s operations aiming to identify potentially risky activities, general principles, rules of conduct, monitoring tools, administrative procedures, training programs, and disciplinary tools designed to prevent, as much as possible, the occurrence of the abovementioned crimes.

The 231 Model includes a General Section explaining its function and principles, as well as the content of Legislative Decree No. 231/2001, other main reference statutes, and the central section: the identification of at-risk activities, the definition of protocols, the modus operandi, the information flows, the training activities, the disciplinary system and updates.

The Model is completed by its Annexes, which are an integral part of the 231 Model itself.