Organization Model

Legislative Decree No. 231 of June 8, 2001, introduced a system of administrative liability for entities in the Italian legal system for certain offenses committed by directors, managers, or employees in the interest or advantage of the entity itself.

TotalEnergies EP Italia S.p.A. (formerly Total E&P Italia SPA) has strengthened its Internal Control and Risk Management system by adopting its own Organization, Management, and Control Model (Model), which provides a structured and comprehensive system of guiding principles, operating procedures, and other specific safeguards, inspired by sound business management criteria and aimed, among other things, at preventing the commission of the offenses provided for by the Decree by those who work with TotalEnergies EP Italia S.p.A. in various capacities.

Following its initial adoption, the Model has been updated and improved in light of jurisprudential and doctrinal developments as well as regulatory evolution of the Decree and organizational changes within TotalEnergies EP Italia S.p.A.

In addition to adopting the Model, TotalEnergies EP Italia S.p.A. has approved its own Code of Ethics, which is an integral part of the Model itself.

The adoption of the Model and the related Code of Ethics promotes rigor, transparency, and a sense of responsibility in internal and external relations, while offering TotalEnergies EP Italia S.p.A. the best guarantees of efficient and proper management through the introduction of procedures useful for managing potential risk situations.

The task of overseeing the effectiveness and adequacy of the Model has been entrusted by the Board of Directors of TotalEnergies EP Italia S.p.A. to a specific Supervisory Body, which also has the task of receiving any reports of possible violations of the Model and/or the Code of Ethics, as well as providing clarifications on any related doubts.

The Supervisory Body of TotalEnergies EP Italia S.p.A. can be reached at the following email address: [email protected]

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