Model pursuant to Italian Legislative Decree 231/2001

In recent years there has been a rapid increase in binding or self-regulatory regulations, both nationwide and internationally, mainly aimed to promote the transparency of the corporate Governance structures and relevant behaviour.

In this context, the Italian Legislative Decree 231/2001 has introduced a new form of corporate responsibility, for the first time in Italy, defined as administrative but substantially of a criminal nature, for certain types of crimes committed by a Company’s directors and employees, as well as by persons who act in the name of and on behalf of the Company.

In compliance with the provisions of the Italian Legislative Decree 231/01, Arexons S.p.A. has put in place an Organisation, Management and Control Model that summarises the rules, values, ideas and principles which all employees, external associates and contractual counterparts must comply with when operating in the name and/or on behalf of Arexons S.p.A. subject to the application of the sanctions set forth in the Disciplinary Code.

The Model of Arexons S.p.A., updated to its latest edition by resolution of the Board of Directors on 26/03/2018, consists of the following documents:

• General part
• Special part
• The crimes pursuant to Italian Legislative Decree 23101 as amended and added
• Manual of procedures
• SB Statut
• Annex A_ Code of Conduct and Business Ethics_ (CoBE) PETRONAS & supplement for Italy
• Annex B_ Manual ABC
• Annex C_ Antitrust Code of Conduct
• Annex D_ Guidelines

All Third-Party Recipients, external collaborators and contractual counterparties, in the execution of the tasks assigned to them, must comply with the rules, procedures and principles contained in the Model, to the extent applicable to them, and may direct requests for information on the Arexons Model SpA to:

SUPERVISORY BODY, Arexons S.p.A., Via Antica di Cassano, 23–20063 Cernusco Sul Naviglio (MI);

or to the e-mail address:

odvarexons@pli-petronas.com