By resolution of its Board of Directors dated2 March 2026, GH Italia S.p.A. adopted itsOrganisational, Management and Control Model pursuant to Article 6 ofItalian Legislative Decree No. 231/2001, with the aim of establishing a system of procedures and internal controls designed to prevent the commission of offences within the Company's areas of risk and to mitigate the risk of corporate liability.

The Model, as approved by the Board of Directors, consists of aGeneral Section, which outlines the principles governing corporate liability for criminal offences, the preventive functions performed by the Model, and the duties and responsibilities of theSupervisory Body (Organismo di Vigilanza), as well as aSpecial Section, which identifies the specific categories of offences to be prevented.

TheGeneral Section is hereby published to ensure that all individuals and entities who, in any capacity, act for or on behalf of GH Italia S.p.A. conduct their activities in accordance with the principles and values set forth in the Organisational, Management and Control Model.