Studio

Our vision is to become one of the most important and internationally recognized architecture firms for architectural quality. We want to be recognized as leaders in the sector, both for our ability to create innovative, high-level projects and for our reputation for reliability and professionalism. We aim to collaborate with prestigious clients, real estate companies, and hotel chains, creating projects that leave an indelible mark on the architectural landscape.

Our mission is to create unique, high-quality architectural spaces, customized to meet the needs and desires of our clients. We are committed to ensuring that every project is completed on time and on budget, exceeding expectations and delivering excellent results. We are driven by a passion for architecture and a desire to create distinctive buildings that blend harmoniously with their surroundings.

1. INTRODUCTION

Giaquinto Architetti Associati S.r.l. (also GAA s.r.l.), a single-member architecture firm (hereinafter referred to as"GAA"and/or "Company") intend to adopt this Corporate Code of Ethics (hereinafter also referred to as the "Code"), which contains the general principles of fairness, transparency, legality, and moral integrity. these principles represent an essential prerequisite for carrying out activities and achieving the productive, economic, and social objectives pursued by the Company.

In particular, this Corporate Code of Ethics defines:

• rules of conduct in relations with external operators, collaborators, consultants, the market, and the environment, to whom the Company provides information about its activities (internal and external), requiring compliance by all parties involved (shareholders, employees, collaborators, consultants, and—to the extent applicable—external operators);
• rules governing the organization and management of professional activities, with the aim of achieving an effective and efficient system for planning, executing, and monitoring activities, capable of ensuring constant compliance with the rules of conduct and preventing any violation thereof by any person acting on behalf of the Company.

This document is not intended to be a tool for resolving disputes of any kind, but rather a point of reference for each operator and a reminder to adhere to basic ethical principles in the daily conduct of their work.

2. Dissemination and updating
This Code has been widely disseminated within GAA and is available to any party interacting with the Company. It is also published on the GAA website.

Each member, employee, collaborator, and consultant of GAA is required to be familiar with and comply with the rules contained in this Code. Through the use of appropriate information, prevention, and control tools, GAA carefully verifies compliance with the Code and, if necessary, takes corrective action. The Company Code of Ethics has been drawn up on the basis of the Guidelines issued by Confindustria pursuant to Legislative Decree 231/2001 and subsequent amendments and additions on the subject of "Administrative Responsibility of the Company" and may be amended and/or supplemented at any time if the need arises.

3. RELATIONS WITH EXTERNAL OPERATORS

3.1 Competition
GAA's corporate policy is based on the principles of free and fair competition.

All actions taken in the course of professional activities are aimed at achieving competitive results that reward the efficiency, skills, and experience of our resources.

GAA and its collaborators must maintain correct behavior in matters of corporate interest, with particular reference to relations with external parties, whether private or public operators. Any action that could alter fair competition is prohibited for anyone acting on behalf of GAA and is contrary to company policy. Furthermore, the pursuit of company interests does not justify conduct (by shareholders, employees, collaborators, and consultants) that does not comply with the rules of this Code and respect applicable regulations.

In all external communications, information about the company and its activities must be truthful, clear, and verifiable.

3.2 Relationships

3.2.1 External partners
The relationships and dealings that the Company undertakes with any partner, whether public or private, are based on principles of fairness, transparency, and verifiability. In particular, with regard to relations with the public administration, the Company proposes and shares compliance with the rules laid down in the code of conduct for public employees. Therefore, no gifts are permitted that may appear to exceed normal commercial or courtesy practices and in any case are intended to obtain favorable treatment in the conduct of professional activities.

With regard to representatives or employees of public administrations, it is prohibited to seek and establish personal relationships of favor, influence, and interference that could directly or indirectly influence the outcome of the relationship.

Offers of goods or other benefits to representatives, officials, or employees of public administrations, including through intermediaries, are also prohibited, except in the case of gifts of modest value, in accordance with customary practice and provided that they cannot be construed as seeking undue favors. GAA does not distribute contributions, benefits, or other advantages to political parties and trade unions (or their representatives), except in accordance with the general principle of transparency and in compliance with applicable regulations.

3.2.2 Customers and Clients
GAA's policy is based on the excellence of the services provided, with the aim of fully satisfying customers and other parties involved in the business, in accordance with the principles of diligence, competence, professionalism, fairness, and transparency.

Data relating to customer satisfaction monitoring is constantly reviewed with the aim of continuous improvement in accordance with corporate quality standards.

In its relations with customers, GAA ensures fairness and clarity in commercial negotiations and in the assumption of contractual obligations, as well as faithful and diligent contractual performance. When participating in tenders and in private commercial negotiations, GAA carefully assesses the appropriateness and feasibility of the services requested, paying particular attention to technical and economic conditions and noting, where possible, any potential anomalies.

All offers are prepared in full compliance with quality standards, employee remuneration levels, and current safety and environmental protection measures.

GAA does not resort to litigation except in specific cases where its legitimate claims are not satisfactorily met by the other party.

In any negotiation, GAA avoids situations in which the parties involved are or could potentially appear to be in a conflict of interest.

3.2.3 Suppliers
Relations with GAA suppliers (including consulting services, financial contracts, etc.) are governed by the provisions of this Code and are subject to constant and careful monitoring by the Company.

It should be noted that GAA uses suppliers and subcontractors who operate in compliance with current legislation and the rules set out in this Code. The selection of suppliers and the determination of purchasing conditions are therefore based on an objective assessment of the quality and price of the services requested, and the ability to provide and guarantee timely services at a level appropriate to the Company's needs.

Under no circumstances shall one supplier be preferred over another on the basis of personal relationships, favoritism, or advantages other than those inherent in the exclusive interest and benefit of the Company.

4. Environment
In consideration of the rights of future generations, the environment is a primary asset that GAA is committed to safeguarding. When promoting, designing, or commissioning the design of construction projects, the Company plans its activities by seeking a balance between economic initiatives and unavoidable environmental needs.

GAA is therefore committed to improving the environmental and landscape impact of its activities, as well as preventing risks to populations and the environment, not only in compliance with current legislation.

GAA is committed to spreading and consolidating a culture of environmental protection and pollution prevention among all its partners, collaborators, consultants, subcontractors, and customers, developing awareness of risks and promoting responsible behavior by all parties involved.

2. RELATIONSHIPS WITH COLLEAGUES

4.1 Work
Human resources are the main factor in the success of any business venture. GAA promotes a framework of mutual loyalty and trust between employers, employees, collaborators, and consultants. Workers are managed in full compliance with the contractual regulations of their sector, as well as tax, social security, and insurance regulations.

GAA will provide its employees and/or collaborators and/or candidates with equal employment opportunities, without any discrimination based on race, color, religion, sexual orientation, disability, nationality, or any other characteristic protected by the laws and regulations to which GAA is subject.

Disparities are not considered discrimination if they can be justified on the basis of objective criteria.

GAA promotes the continuous improvement of the professionalism of its employees, collaborators, and consultants, including through training initiatives.

Furthermore, and within the scope of its capabilities, GAA undertakes to ensure that all partners, employees, collaborators, and consultants, as well as the personnel of other companies or professionals with whom joint or coordinated activities are carried out (even temporarily), to observe constant compliance with the laws and regulations in force, as well as with the organizational and procedural rules adopted, with particular reference to those expressly provided for in the organization, management, and control model for the prevention of crimes.

4.2 Health and safety
GAA is committed to creating working conditions that protect the physical and mental well-being and health of its employees and respect their moral responsibility, avoiding discrimination, unlawful influence, and undue hardship. The Company carries out its activities in technical, organizational, and economic conditions that ensure adequate accident prevention in a safe and healthy working environment.

GAA promotes a culture of "safety" within the company by developing risk awareness and promoting responsibility and prevention activities among all members, employees, collaborators, and consultants.

4.3 Combating gender-based violence and harassment in the workplace
GAA strongly condemns all forms of harassment, sexual violence, and gender-based violence perpetrated in the workplace.

Employees who believe they have been subjected to harassment or discrimination may report the incident to company management, who will assess whether there has been a violation of this Code.

Disparities are not considered discrimination if they can be justified on the basis of objective criteria.

In order to prevent the occurrence of any form of harassment and violence in the workplace, GAA adopts the following set of rules and deterrent behaviors, aimed at providing maximum protection for its employees and/or collaborators:

• consolidation of a workplace free from prejudice, respecting the professionalism of everyone involved in the company's professional activities;
• condemnation of all forms of slander, defamation, false accusations, and discriminatory behavior by anyone who is part of the GAA company;
• reporting, prosecuting, and punishing all forms of harassment and violence to the competent authorities;
• material and psychological assistance to any victim of abuse.

5. IMPLEMENTATION METHODS

5.1 Prevention
In compliance with current legislation and with a view to planning and managing company activities aimed at efficiency, fairness, transparency, and quality of services rendered, GAA uses appropriate organizational and management measures to prevent unlawful conduct or conduct contrary to the guidelines of this Code by any person acting on its behalf. Given the complex organization of sectors divided by discipline, GAA adopts a system of delegation of powers and functions, providing in explicit and specific terms for the assignment of tasks to persons with the appropriate skills and competence.

5.2 Controls
GAA adopts specific control procedures to ensure that anyone acting on its behalf complies with the rules of conduct set out in this Code and with the provisions of current legislation.

5.3 Sanctions
Compliance by the Company's employees, collaborators, and consultants with the provisions of this Corporate Code of Ethics shall be considered an essential part of their contractual obligations pursuant to Article 2104 of the Italian Civil Code. Conversely, violation of the rules of the Code by any of the above-mentioned persons may constitute a breach of the primary obligations of the employment relationship or a disciplinary offense, with all legal consequences.