Bormioli Pharma S.p.A. has adopted an Organizational, Management and Control Model in accordance with Legislative Decree No. 231/2001, aimed at ensuring that all parts of the company operate with integrity and transparency in all activities and in relationships with public and private entities. These measures are adopted in full alignment with the compliance framework of the Gerresheimer Group, of which Bormioli Pharma S.p.A. is part, and are fully consistent with the Group’s compliance policies. The Model also aims to ensure the highest standards of professional competence, quality, integrity, and ethical conduct.

The responsibility for monitoring the adequacy, effectiveness, and proper functioning of the Model lies with the Supervisory Board (Organismo di Vigilanza), an independent body autonomous from management.

Bormioli Pharma S.p.A. provides the possibility of reporting, in a fully confidential manner, potential unlawful acts relevant under Legislative Decree No. 231/2001 through the following channels:

• “Integrity Line” platform;
• e-mail: organismo.vigilanza@bormiolipharma.com;
• regular mail to: Viale Giovanni Falcone n.48/A, Parma, 43122 Italy, addressed to “Organismo di Vigilanza.”

Bormioli Pharma is also equipped with a Code of Ethics, an integral and substantial part of the Organizational, Management and Control Model, which sets out the ethical principles and behavioral rules that the company upholds, defining the general standards to which all individuals operating within the corporate context are subject. The Code of Ethics reflects Bormioli Pharma’s commitment to promoting responsible, sustainable behaviors that comply with the highest standards of quality and integrity.

Bormioli Pharma conducts its business with fairness, honesty, integrity, and transparency.

This procedure is inspired by the principles of conduct set out in the Organizational, Management and Control Model adopted by the Company pursuant to Legislative Decree No. 231/2001, and in Bormioli Pharma’s Code of Ethics. As a Compliance Standard, this procedure represents a prescriptive document applicable to all processes within Bormioli Pharma, aimed at providing employees with clear and transparent rules to ensure full compliance with anti-corruption legislation, in full alignment with the compliance framework of the Gerresheimer Group.

The principles of fair competition are a cornerstone of Bormioli Pharma S.p.A.’s corporate culture (“Bormioli” or the “Company”). In the performance of their professional activities, Bormioli employees are therefore required to fully comply with antitrust regulations.

Bormioli Pharma has adopted an Antitrust Conduct Manual, which serves as a reference tool for its employees who, on behalf of the Company, interact with competitors, customers, suppliers, and other stakeholders. The Manual is designed to help identify, prevent, and effectively address—either independently or with the support of the Compliance Officer—conduct that could potentially infringe competition law.

To further protect all stakeholders, Bormioli Pharma has updated its Whistleblowing Procedure in line

with the new provisions introduced by Directive (EU) 2019/1937 (the so-called EU Whistleblowing Directive), as transposed by EU Member States.

This Procedure forms an integral part of the Organizational, Management and Control Model adopted pursuant to Legislative Decree No. 231/2001 and sets out the requirements and methods through which employees, collaborators, and third parties may report, including anonymously, suspected unlawful conduct in breach of the Model’s provisions, as well as facts or behaviors constituting any of the offenses under Legislative Decree No. 231/2001 or other activities that are non-compliant with laws, regulations, internal procedures, and company policies, or otherwise capable of causing damage or harm, including reputational damage, to Bormioli Pharma.

Reports can be submitted by employees, collaborators, and third parties through the dedicated portal available at the following link: https://bormiolipharma.integrityline.com.

The EQS Integrity Line portal allows any party, including customers and suppliers, to submit reports—also anonymously—concerning behaviors, risks, offenses, or irregularities, whether committed or attempted, that may harm the interests of Bormioli Pharma or otherwise constitute violations of the Model and the Code of Ethics.

In addition to this EQS portal, the Gerresheimer Group has implemented a Group whistleblowing reporting channel available at the following link: https://www.gerresheimer.com/en/investors/corporate-governance/whistleblowing-system

Further information is available in Bormioli Pharma’s Whistleblowing Policy.

As a supplier of pharmaceutical packaging, we are committed to offering solutions that have a positive impact on people’s well-being and the future of our planet. For this reason, we have drafted and adopted a series of documents reaffirming the principles, objectives, and behavioral standards that inspire Bormioli Pharma’s corporate culture and business practices.

Through the ESG Policy & Governance, we identify Bormioli Pharma’s sustainability objectives, in line with selected UN Agenda 2030 Sustainable Development Goals (SDGs), and define the structures and processes to achieve them. Through the Sustainability Report, we measure and communicate to our stakeholders the activities carried out and our performance against these targets.

The Corporate Human Rights Policy sets out the principles and commitments undertaken by Bormioli Pharma for the protection and promotion of human rights. These rights, already established in the Code of Ethics, lie at the heart of our corporate culture and are considered a fundamental element in managing our business responsibly and, at the same time, in contributing to the well-being of the communities in which we operate.

The Corporate Policy on Health, Safety and Environment defines the criteria guiding our management of Quality, Safety, and Environmental processes, as described in ISO 9001, ISO 15378, ISO 13485, ISO 45001, and ISO 14001 standards. To ensure compliance with these criteria, our systems are subject to periodic verification by independent, internationally accredited certification bodies.