55 RUFFINO | Sustainability Report FY 2021 The aforesaid values are outlined in our Company Code of Ethics and Conduct, which sets out the rules of conduct to respect the ethical and legal requirements. The code is general, hence it does not focus on specific conduct and procedures, which are instead contained in the “Compliance Material”, which includes the policies defined by the CBI Group, procedures, rules of conduct and corporate or departmental handbooks. The Company Code of Ethics and Conduct also outlines issues such as conflict of interest, an- ti-corruption and antitrust, as well as protecting employees from the standpoint of equal oppor- tunities, health and safety in the workplace, protecting the environment and sustainability, protecting personal data and confidentiality, external communications, and local and inter- national legislation regarding the production, sale, marketing and distribution of alcoholic be- verages. The provisions set out in the code apply to all company roles – employees, executives and ma- nagers – and to all those – in whatever role, al- beit occasional – who operate in the name of and on behalf of the companies in the Group. In order to ensure the correct application of the aforesaid values and principles, hence to safe- guard the company reputation, in FY 2013 7 , we implemented the Organization, Management and Control Model, in accordance with Italian Legislative Decree 231/01 (“Modello 231”) and in line with the Confindustria guidelines for the cre- ation of organization, management and control models. The “Modello 231” constitutes the Annex to the Company Code of Ethics and Conduct, adding specific principles, values and ethical rules that must guide the activities and conduct of the Ruf- fino Group. The contents apply to the corporate roles of the Group, the employees of every company and to all others who, in whatever way, operate in the inte- rests of the companies or with whom the Group establishes a rapport. With the implementation of “Modello 231”, the companies set up a Control Body, which is in- dependent, impartial and reports directly to the Board of Directors; it has powers to check the correct applications of what is set out in the do- cument. All the companies in the Ruffino Group pledge to communicate the provisions of the “Modello 231” in order to ensure that all recipients are in- formed, in particular: • The document and Code must be shared with all new employees; • Contracts with external collaborations include an informational note; • Specific and differentiated training is pro- vided depending on the company roles and departments; • Useful tools are available to clarify any doubts regarding the correctness of one’s conduct and its alignment with what is set out in the Code and in the “Modello 231”; • All recipients are informed about updates to the documents. Several ways to communicate violations, even suspected violations, and issues linked to the implementation of the code are available for all recipients of the Company Code of Ethics and Conduct. In particular, employees can contact di- rectly and confidentially: i) their line manager; ii) the HR Department; iii) the Legal Department; iv) the Corporate Compliance Organization 8 . 7 For the companies Ruffino S.r.l. and Tenute Ruffino S.r.l. Società Agricola from FY 2013 and Poderi Ducali Ruffino S.r.l. Società Agricola from FY 2020. 8 Role of the CBI Group’s Corporate Compliance Team.