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CODE OF ETHICS

PREAMBLE

Plan B has adopted this Code of Ethics in order to provide a clear and transparent definition of the values it is inspired by.

Plan B conducts its business in compliance with the principles contained in the Code of Ethics, in the belief that an attitude of respect and collaboration towards all Stakeholders is a precondition for creating value, and the success of a healthy company that reflects the area it is based in, and from where it receives and redistributes resources. 

In particular, Plan B pursues the following goals for the common good and sustainable development when conducting its business, and in relation to the environmental and social context of the areas it operates in:

  • the procurement of products from manufacturers and suppliers who promote a fairer and more sustainable, ethical and responsible economy that respects people and protects the environment;
  • the creation of products with a low environmental impact;
  • the promotion and support of initiatives that support sustainable development and environmental protection, the fight against racial discrimination, vulnerable categories, and health and safety;
  • the provision of support for and collaboration with organizations that operate with respect for the environment and people.        
1. USER’S GUIDE TO THE CODE OF ETHICS

Recipients of the Code of Ethics

1.1 “Recipients” of the Code of Ethics: Directors, members of control bodies, Human Resources, as well as Plan B’s Other Collaborators, including temporary ones.

1.2 “Human Resources”: all employees, temporary employees and posted workers, as well as quasi-subordinate workers and other individuals who are part of the Company’s staff, regardless of the type of contract and reference legislation.

1.3 “Other Collaborators”: for example, other individuals who occasionally collaborate with Plan B, regardless of their professional category or the type of contract.

1.4 Other parties that must comply with the Code of Ethics include Manufacturers, Suppliers, “Licensees”, commercial and corporate partners (hereinafter referred to as “Partners”) and “Other Parties” with whom Plan B has a contractual relationship, as well as anyone undertaking activities in the name of or on behalf of Plan B, or under the control thereof, whether they are natural or legal persons. 

1.5 Recipients are obliged, where applicable, to observe the principles contained in the Code of Ethics and shall be subject to penalties for the breach of any of its provisions. The penalties depend on the type of relationship that binds them to Plan B.

Dissemination and awareness of the Code of Ethics

1.6 The Code of Ethics is published on the Company’s website (www.anti-do-to.com).

1.7 The Company ensures the maximum dissemination and awareness of this Code of Ethics at all levels of its organization. By virtue of the employment relationship or the contract that binds them to Plan B, all Recipients are required to comply with the Code.

1.8 With regard to the contractual relationships with external parties, referred to in Article 1.5, Plan B requires the counterparty to read and accept this Code of Ethics, unless said party has its own code of ethics, in which case Plan B and the counterparty shall both acknowledge that they have read the respective codes of conduct, on the condition that the principles contained in the counterparty’s Code of Ethics are compatible with those of Plan B.

 

2.GENERAL PRINCIPLES

Impartiality

2.1 Plan B is opposed to all forms of discrimination, including social discrimination, racism, xenophobia and intolerance.

2.2 Plan B undertakes to avoid any discrimination in its conduct and to respect, in relations with its stakeholders, any differences in age, gender, sexual orientation and identity, ethnicity, religion, health status, political and trade union affiliation, language or diverse abilities.

Probity

2.3 Within the scope of activities carried out for Plan B, Recipients are required to comply with the laws in force for each of the set of rules within which the Company and the Code of Ethics operates. In no event may the pursuit of Plan B’s interests be used to justify failure to comply with said laws.

2.4 Plan B is against all forms of violence. All of Plan B’s activities must always be carried out with honesty, integrity and fairness with respect to the stakeholders in question, and within a framework of fair business practices.

2.5 In particular, Plan B expects its Human Resources to maintain high ethical and professional standards when carrying out their jobs, and to comply with the law, in order to strengthen mutual trust and consolidate the Company’s reputation, while avoiding any behavior that could damage it. They must maintain integrity and probity in their relationships with each other and with Plan B’s Directors and shareholders, competitors, representatives of Public Authorities and with all third parties in general, whether they are negotiating counterparties or other stakeholders.

Conduct in the event of potential conflicts of interest

2.6 When conducting any type of business for or on behalf of Plan B, Recipients must always avoid situations where there is an actual or apparent conflict of interest between themselves and the other parties involved. Recipients are required to report said situations.

2.7 Recipients must not seek to derive any undue personal benefit, pursue interests other than Plan B’s corporate goals, or act against the contractual and/or fiduciary duties that bind them to the Company.

2.8 Particular attention must also be paid, where applicable, when carrying out transactions with parties they are closely associated with. These must be carried out in full compliance with the applicable laws and regulations and must ensure full transparency, correctness and good reason for said transactions.

Transparency and completeness of information

2.9 In relations with third parties, whether they are negotiating counterparts or other stakeholders, Plan B’s Human Resources are required to provide complete, transparent, understandable and accurate information, without prejudice to the protection of confidentiality concerning information and personal data (see Articles 9 and 10), in such a way that third parties entering into a relationship with the Company are able to make independent decisions, while being aware of the interests involved, any alternatives and any relevant consequences. In particular, when stipulating any contract, Plan B will specify the conduct that must be maintained in all foreseen circumstances, so it is clear and understandable to the contracting parties.

Sustainability and social impact

2.10 Plan B is committed to creating a positive impact on society and the environment, in order to create long-term sustainable value for all stakeholders, as well as generate profit. Sustainability is an integral part of its business model: to create favorable conditions for social and environmental prosperity, today and in the future.

2.11 Plan B undertakes to build a relationship of trust and continuous dialogue with Stakeholders, informing and involving them in everything that interests and/or concerns them.

2.12 Plan B promotes a culture of environmentally-sustainable production, based on making continuous improvements for the protection of the environment, minimizing the environmental impact of its activities to protect the growth and health of people, and creating better conditions for future generations. 

2.13 Sustainability means offering a range of products whose entire production line respects human and social rights and the strictest environmental, health and safety standards, all based on transparency and continuous dialogue with Stakeholders. To this end, Plan B undertakes to adopt environmentally responsible behavior, and act in strict compliance with all applicable regulations, as well as within the boundaries established by any permits or regulations received from competent bodies.

3. HUMAN RESOURCES

3.1 Relations between colleagues, even if they are at different hierarchical levels and in respect of their roles, must always be based on the principles of civil coexistence, loyalty and correctness, and must maintain mutual respect for the rights and freedom of the other person.

3.2 Managers responsible for organizational structures and specific activities must exercise the powers that come with their job and/or the authorization received in an objective and balanced manner, while maintaining loyalty to Plan B and its administrative bodies, and at the same time respecting the dignity of their co-workers, whose professional growth they are responsible for. With regard to the procedures for exercising the powers that have been granted, refer to the Company’s Articles of Association and the system for the delegation of powers.

3.3 When carrying out their duties, all Human Resources must cooperate fully by observing the provisions for the execution and protocol of the work assigned by their manager(s) and the Company in general.

Human resource management policy

3.4 Plan B recognizes the centrality and importance of the individual and of each individual’s contribution in the sharing of individual skills; for this reason, it is committed to creating a serene work environment in which everyone is able to work in compliance with laws, principles and shared ethical values, where every single person is valorized without direct or indirect discrimination.

3.5 Plan B ensures that Human Resources behave and are treated with dignity and respect, within the framework of the provisions of the laws governing employment relations.

3.6 Plan B does not tolerate any form of discrimination, exploitation, harassment, bullying or isolation for either personal or work reasons within its organization; situations of this magnitude will be prosecuted and punished with the termination of the contract of employment or collaborative relationship.

3.7 Plan B shall not apply any disciplinary or contractual sanctions against employees or other collaborators who have legitimately refused to provide a work service that has been unduly requested of them by any person linked to the Company. Plan B shall protect those who provide a detailed report of such situations in good faith, as specified under Article 17.

3.8 Plan B is opposed to “undeclared work” and child/underage labor, as well as any other conduct involving labor exploitation or which offends individual personality. All employees and collaborators are hired through standard employment contracts. Human Resources are duly and fully informed of all the rights, duties and obligations set out in the contract.

3.9 Plan B promotes the cultural growth of its staff and improves their professionalism and personality by providing appropriate training tools.

3.10 The procedures for the selection of new Human Resources and the management of remuneration policies and career paths, are based on purely meritocratic criteria.

4. HEALTH AND SAFETY AT WORK

4.1 Plan B is committed to disseminating and reinforcing the culture of safety and health in the workplace, by developing awareness of the dangers and risks involved, promoting responsible behavior on the part of Human Resources, and working to protect the health and safety of workers, primarily through preventive measures.

4.2 The company’s activities are carried out in compliance with existing Occupational Health and Safety legislation. In particular, the OHS management system is based on the following principles:

  • assessing and managing risk, including unavoidable risks;
  • dealing with risks at their source;
  • adapting the working environment to the people in it, particularly with regard to the design of workstations and the choice of working methods and tools;
  • taking technical developments into account;
  • replacing dangerous items and practices with non-dangerous or less dangerous alternatives;
  • planning prevention with consistent actions that integrate technique, work organization, working conditions, social relations and the influence of workplace factors;
  • giving priority to collective protection measures over individual protection measures;
  • providing workers with the necessary instructions.
5. RELATIONS WITH PUBLIC AUTHORITIES

5.1 Plan B’s Human Resources must maintain lawful, ethical and respectful relationships with authorities and public institutions, ensuring that their conduct in all areas that Plan B operates in conforms to the principles of fairness and transparency when dealing with Public Authorities and their representatives. In particular:

  • when making a request to a Public Authority for the provision of measures relating to company activities;
  • on any occasion that involves contact with bodies/parties engaged in carrying out inspections or surveys at Plan B’s sites to verify compliance with legal provisions and/or requirements;
  • on any occasion that involves contact with a Public Authority for institutional, commercial or supply purposes;
  • when fulfilling obligations or regulations established by a Public Authority.

5.2         Plan B ensures correctness and transparency in its business dealings and negotiations with Public Authorities, as well as in the execution of any legal or regulation requirements dictated by the same.

5.3         Plan B’s relations with public officials (including public employees - regardless of whether or not they are in charge of a public service - and public service concessionaires) are based on transparency, loyalty and fairness: Plan B does not intend to create the slightest suspicion of wanting to unduly influence these subjects to obtain benefits by illicit means.

5.4         Plan B condemns any behavior that may constitute the corruption of private individuals, set out in detail under Article 7.6 of this document. Any attempt to extort, bribe or induce a public official or public service representative to provide an undue advantage must be reported without delay.

5.5         Recipients of the Code of Ethics must disclose any personal business relationships or financial activities undertaken with public officials.

5.6         In light of the above, Recipient’s must not:

  • attempt to improperly influence the decisions of the various Administrations concerned, with particular regard to officials who negotiate or make decisions on behalf of said administrations;
  • promise or grant money, goods, favorable conditions or other advantages, in any form, directly or indirectly, to any individual (regardless of whether the individual in question is a manager, officer or employee of a Public Authority or a private individual employed in public services, or directly related or related by marriage, cohabiting or in any other way associated with said individual), in order to incite said individual to perform an official act or exert undue influence over a decision to promote or favor the Company’s interests, even if it is induced by the illicit pressure or persuasion of said beneficiary. Human Resources are permitted to offer business gifts and courtesies of modest value, as long as they are considered fair and reasonable for any normal business or courtesy relationship. In any event, any gifts or presents will be duly monitored, evaluated and recorded by Plan B;
  • send false or manipulated documents, attest to non-existent requirements or provide guarantees that do not correspond to the truth;
  • unduly procure any other type of advantage (licenses, permits, relief from social security charges, etc.) through deception or trickery (for example: sending false documents or certifying things that are not true);
  • confer professional duties, give or promise gifts, money, or any other advantage to public officials or public employees involved in administrative proceedings, nor engage in any financial activities with them, that could benefit Plan B;
  • alter in any way the function of the IT or on-line system of a Public Authority or third-party, or in any way unlawfully modify the data, information or programs contained in any of the aforementioned systems;
  • unlawfully receive contributions, funding, facilitated loans or any other disbursements granted or paid by public authorities, through the use or submission of false or untruthful documents, or the omission of information;
  • use contributions, subsidies or funding designated for public works or activities in the public’s interest for purposes other than those for which the same were granted;
  • illegally exchange information on bids with participants of any tenders or public procedures.

5.7         Any corrupt conduct that constitutes a criminal offence, even if it is done in foreign countries where such conduct is not punishable or otherwise prohibited, is a violation of Plan B's institutional policy

5.8         In general terms, relations with a Public Authority on behalf of Plan B must be managed by delegated or duly authorized parties.

5.9         Plan B acts in compliance with the law and upholds, within its purview, the proper administration of justice.

5.10      When conducting its business, Plan B operates lawfully and properly by cooperating with any judicial authority, law enforcement agency or public official that has the power to investigate it.

5.11      In the event of a judicial proceeding, an investigation or inspection by a Public Authority or Supervisory Authorities, no one may destroy or alter any records, minutes, accounting records or other type of document, or lie or make false statements to the competent authorities.

5.12      No one must try to persuade others to provide false or misleading information to the competent authorities.

5.13      No one may confer professional appointments, give or promise gifts, money or other benefits to those carrying out verifications or inspections, or to the competent authorities, nor engage in any financial activities with them.

6. DONATIONS FOR POLITICAL PURPOSES

6.1 These contributions require the prior approval of the Company’s Board of Directors and must be made within the limits and in the forms provided for by the applicable regulations.

7. RELATIONS WITH SUPPLIERS, LICENSEES, PARTNERS AND OTHER CONTRACTUAL COUNTERPARTIES

7.1 Plan B establishes relationships with Suppliers, Manufacturers, Licensees and Partners solely on the basis of trust, quality, competitiveness and professionalism, and avoids agreements with parties that have, for example, questionable respect for the environment, working conditions and human rights.

7.2 In particular, Plan B’s evaluation criteria for selecting Suppliers and Licensees also include - in addition to quality and competitiveness - reputation, reliability, professionalism, efficiency and sustainability (environmental and ethical certifications), in order to establish a solid and long-lasting fiduciary relationship. Plan B avoids agreements with suppliers that have a dubious reputation that may not reflect the values set out in this Code of Ethics, which are in line with the principles of the United Nations Global Compact, such as respect for the environment, working conditions, human rights and the principles of legality, respect for competition and the fight against corruption. 

7.3 The same principles are adopted in the evaluation of Partners, who are required to share the values set out in this Code of Ethics, also to safeguard the reputation of Plan B’s brand and company.

7.4 Plan B expects that no undue pressure will be put on Suppliers, Licensees and Partners to perform services that are not contractually provided for.

7.5 In requesting adherence to this Code of Ethics, Plan B expects Suppliers, Licensees, Partners and Other Parties to behave in compliance with the principles that apply to them. Contradictory behavior may be considered a serious breach of the duties of correctness and good faith set out in the contract with Plan B, and this may cause damage to the fiduciary relationship and therefore become a just cause for termination of the contract itself.

7.6 No Recipient of this Code of Ethics may promise or grant money, in-kind gifts, facilitation or any other benefits, in any form, directly or indirectly, to any individual representing any of Plan B’s counterparties (whether they are a director, general manager, manager or employee of a private company, a statutory auditor or liquidator) for the purpose of influencing a decision or in return for them performing actions or concluding business agreements or, in general, to promote or favor Plan B’s interests or cause damage to a competitor. Business gifts and courtesies of modest value are allowed, as long as they are considered fair and reasonable according to local laws, transparent for reasons related to legitimate and socially accepted interests, or of an occasional nature, in order to avoid that their contents or occurrence could lead any independent third party to question the good faith of Human Resources or Plan B. Cash gifts are expressly prohibited. All Human Resources are obliged to ensure that they are duly informed about local practices and to evaluate said practices adequately, taking the interests and reputation of Plan B into consideration. In any event, the practices in use regarding gifts and presents will be duly monitored, evaluated and recorded by Plan B.

8. PROTECTION OF ETHICAL STANDARDS IN SUPPLIES

8.1 With a view to ensuring that its procurement activities conform to its adopted ethical principles, Plan B undertakes to introduce social requirements for certain supplies: for example, the presence of an environmental management system or workers protection system.

8.2 To this end, contractual clauses providing for the following can be included in contracts with suppliers:

  • self-certification or declaration by the supplier, regarding adherence to specific social obligations: for example, the adoption of measures that guarantee workers respect for fundamental rights, the principle of equality and non-discrimination, protection against child labor and compliance with the quality standards of the product or service.
  • the possibility for Plan B to carry out checks at the factories or offices of the supplier company, in order to verify the fulfilment of these requirements.
9. CUSTOMERS

9.1 Plan B recognizes the customer’s central role in its business and undertakes to fully understand their needs and to provide products and services that meet the latter, in order to achieve a high level of customer satisfaction.

9.2 Plan B is committed to communicating with its customers in a clear and transparent manner and to providing safe products and services. With regard to products, Plan B is committed to offering customers a high standard of excellence, quality, health and safety. All products will be made ethically and responsibly. The most important principles governing the relationship between the products sold by Plan B and its customers are as follows:

  • Responsible design and ethical and responsible production of garments, achieved by evaluating the environmental impact of its products (recycling, biodegradability, eco-friendly textile fibers)
  • Compliance with the strictest health and safety standards for products
  • Product promotion based on objective standards, with no distorted descriptions or characteristics and no false or ambiguous information that could mislead customers or third parties.

9.3 Plan B guarantees the security of any means of payment used in its shops (whether physical or online), in order to ensure adequate traceability of billing and collection procedures, customer data protection and the prevention of fraud.

10. THE ENVIRONMENT

10.1 Plan B believes that safeguarding the environment is a necessity for long-term survival and therefore protecting the environment is one of the company’s main priorities. To achieve this, Plan B undertakes to comply with the environmental laws and regulations that apply to its activities, to evaluate the environmental impact of its products, and to choose Suppliers and Manufacturers who promote environmental protection and adopt systems and technologies that aim to reduce environmental impact as much as possible.

11.THE COMMUNITY

11.1 Plan B encourages and supports the promotion of human rights in the local, national and international communities in which it operates. Plan B participates in socially responsible practices that create value within the community and the company. This support is provided both through the promotion and/or organization of events and/or initiatives with high social and cultural value, and by supporting organizations that operate in the voluntary sector.

12. ACCOUNTING TRANSPARENCY AND INTERNAL CONTROLS

Corporate communications and accounting records

12.1 Accounting transparency is based on the truth, accuracy and completeness of the basic information in the related accounting records. Those responsible for the company’s accounting records are required to take action to ensure that all accounting events are represented in the accounting records correctly and promptly.

12.2 A record is kept of all supporting documentation, which allows: (i) accounts to be recorded more easily; (ii) authorization levels to be identified; and (iii) transactions to be reconstructed accurately and the probability of interpretation errors to be reduced.

12.3 Each entry must reflect exactly what is shown in the supporting documentation. It is the job of those responsible for the company’s accounting records to ensure that the documentation is easily traceable and that the entries are based on logical criteria.

Internal Controls

12.4 Plan B’s policy is to promote a control culture at all levels by ensuring awareness of internal control procedures and the positive effects these have on improving efficiency.

12.5 Internal controls are all the tools necessary or useful for supervising, managing and verifying the Company’s activities, with the aim of ensuring the credibility, accuracy, reliability and timeliness of the information provided to corporate bodies and the market; safeguarding company assets; checking the effectiveness of company processes; and guaranteeing compliance with laws and regulations, as well as with the Articles of Association and internal procedures.

12.6 All levels of the organizational structure are responsible, in various ways, for creating an effective internal control and risk management system; consequently, directors, members of control bodies and all Human Resources, each within their own role, must contribute to the definition, operation and monitoring of the internal control and risk management system.

12.7 Within the scope of their duties, the heads of organizational units are required to participate in the internal control and risk management system and to involve their co-workers.

12.8 The appointed accounting firm must always have free access to all the data, documentation and information needed to carry out audits.

12.9 Directors and Human Resources must not impede or hinder in any way the auditing activities carried out by statutory auditors, shareholders or the accounting firm.

12.10 In view of the above:

  • Equity, assets, receivables and shares must be entered with the correct values, and the same must not be assigned values above or below what they actually are;
  • Performing share capital transactions, or any other type of transaction that involves the use of non-distributable profits or reserves required by law is prohibited;
  • the share capital may not be reduced, except in the event of losses or depreciation;
  • Directors cannot purchase or underwrite company shares or quotas unless they use their own funds;
  • only the objectives in the Articles of Association can be pursued;
  • the management of the company’s equity must be in line with Plan B’s organizational and business policies, which operate according to the principles of transparency and morality;
  • shareholders may not be released from the obligation to make contributions.

12.11    The same principles must be adopted in evaluations and any other extra-ordinary operations (mergers, divisions, etc.).

12.12    It is strictly forbidden for any party to influence the regular occurrence and decisions of shareholders’ meetings by seeking to deceive or mislead shareholders.

13. COMPANY COMMUNICATIONS AND CONFIDENTIALITY

13.1 Internal and external company communications must be clear, accurate and truthful in order to avoid inaccurate news and information being made public, or the creation of situations that the company could in any way be held liable for.

13.2 To protect the Company’s reputation, the value of the brand and confidentiality, the disclosure of any information concerning Plan B to the media or general public is managed solely by the spokespersons and organizational structures that are expressly responsible: no other Recipient may disclose information. 

13.3 Confidential information concerning Plan B that has not already been made public, must not be communicated externally, including via digital and social media; the unauthorized dissemination of any content, images, written or audio-video documents owned by Plan B is also prohibited.

13.4 Recipients must not disclose any information that is untrue, defamatory, damaging to Plan B’s image, or detrimental to the dignity of any other external person who is in some way connected to or associated with Plan B.

13.5 Confidential information and documents, work projects and know-how must be appropriately and consistently stored and protected against access from third parties and colleagues who are not directly involved with them. Those who have access to the above for work-related purposes, must in any case follow the instructions and procedures established by the company.

13.6 If a third party should seek to obtain confidential information from a Recipient of this Code of Ethics, either deliberately and/or fraudulently, the latter must promptly notify his/her contact person within the organization.

14. PROTECTION OF PERSONAL DATA

14.1 Plan B adopts organizational and security measures for the correct processing of the personal data in its possession, in compliance with applicable European and national legislation.

14.2 Personal data must be processed on the basis of consent and specific purposes, and must not be disclosed externally without consent. Individuals who have access to these data for work-related purposes must follow the Company’s instructions and procedures.

15. COLLECTIONS AND PAYMENTS

15.1 Plan B conducts its business in full compliance with current anti-money laundering regulations, where applicable, and the provisions issued by the competent Authorities.

15.2 To this end, Human Resources must operate in compliance with company procedures, and avoid carrying out any transactions that are suspicious in terms of fairness and transparency. In particular, it is necessary to verify the available information concerning active and passive counterparties (suppliers, partners, other collaborators) in advance, in order to verify their respectability and the legitimacy of their business;

15.3 Plan B’s counterparties also undertake to operate in such a way as to avoid their involvement in transactions that could potentially favor the laundering of money deriving from illicit or criminal activities.

15.4 With specific reference to the traceability and storage of records, Recipients must observe the following rules:

  • No payments or other money transfers made by or to the company must be made in cash, bearer forms or any other means considered to be a cash equivalent;
  • An accurate and complete record must be kept of all payments and other transfers made by or to the company in the accounting books and mandatory records;
  • Payments must only be made to Recipients for work that has been carried out under a formal contract and/or approved by delegated Subjects;
  • No false, incomplete or misleading entries must be made. Setting up hidden or unregistered funds, depositing funds in personal accounts or any account that does not belong to the Company, and using Company funds or resources without full and proper authorization are also strictly forbidden.
16.PROTECTION OF COMPANY ASSETS

16.1 Plan B’s assets must be managed efficiently and honestly, and therefore all subjects required to comply with this Code of Ethics must contribute to the preservation of the integrity and value of said assets, in order to protect shareholders, creditors and investors.

16.2 Human Resources are responsible for the conservation and protection of all assets and tools entrusted to them by Plan B, and must contribute to ensuring the protection of all company assets by respecting the operational and safety procedures established by the Company.

16.3 The Plan B brand, in all its forms, must be protected and valued. All Recipients must comply with the contractual limitations and provisions governing the use of the brand and the enjoyment of contractual rights.

16.4 In any event, any documents relating to the Company’s activities, equipment, work tools or any other tangible or intangible asset made available and/or supplied by the same, must be used exclusively for Company purposes, using the procedures established by the same. They may not be used for personal purposes, or transferred or made available, even temporarily, to third parties.

17.CRIME PREVENTION

17.1 Plan B expects Recipients, each within the scope of the activities they carry out for Plan B, to not engage in any unlawful conduct stipulated amongst the violations referred to in Legislative Decree 231/2001.

18. IMPLEMENTATION OF THE SANCTIONS SYSTEM

18.1 The Company undertakes to focus on ensuring best practices in relation to its business, ethical and social responsibilities towards its shareholders, human resources and other stakeholders. This Code of Ethics defines the Company’s expectations concerning the Recipients and the responsibilities they must assume to transform these policies into concrete actions.

18.2 The Company and, above all, its directors and managers, undertake to ensure that these policies and expectations are understood and put into practice within the organization. They are accountable to the Company’s control bodies and are required to play an active role in order to implement the commitments set out in the Code of Ethics.

18.3 Breaches of the Code of Ethics are subject to penalties, proportionate to the seriousness of the offense and determined on the basis of the type of relationship that the Recipient in question has with Plan B. Measures also include the termination of the fiduciary relationship with the Company, with the expected and permitted contractual consequences established by current regulations.

18.4 Any sanctions against Human Resources for breaches of the Code of Ethics will be applied in compliance with the provisions of the law and collective bargaining, and will be proportionate to the gravity and nature of the offense. Verification of said breaches/non-compliance, as well as the management of the penalties and sanctions, will be the responsibility of the Company's assigned or delegated bodies or individuals.

18.5 With regard to Other Collaborators, Suppliers, Licensees and Partners, Plan B reserves the right to terminate the contract agreed on with them or to apply other contractual actions, by virtue of clauses specifically provided for this purpose, as set out under Article 7.5.

18.6 The Company Directors will continuously assess and judge this Code of Ethics to ensure it is suited to the   evolution of the company and all relevant primary legislation.

19. REPORTING BREACHES OF THE CODE OF ETHICS

19.1 Any Recipient can report, without delay, a suspected breach of the provisions in this Code of Ethics by one or more Recipients, provided that the report is in good faith and circumstantiated, or based on precise and concordant facts.

19.2 Alternatively, reports can be made using the following communication channels:

  1. a) by e-mail to: ethics@anti-do-to.com;
  2. b) by ordinary mail: reports should be sent to Plan B’s registered office in a sealed envelope, for the confidential and personal attention of the Chairman of the Board of Directors.

19.3      Reports shall be processed promptly using a predefined procedure. Plan B requires that named reports be made, and undertakes to keep the identity of the Reporting Party confidential, without compromising legal obligations or the protection of the rights of Plan B or of those accused wrongly and/or in bad faith.

19.4      Plan B will protect the Reporting Party against any form of retaliation, discrimination and/or penalty in good faith: if such conduct occurs, Plan B will act accordingly.

19.5      Likewise, Plan B may take action under applicable law against those who knowingly make false, unfounded or specious reports.

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