CODE OF CONDUCT & ORGANIZATION MODEL
CK HUTCHISON NETWORKS ITALIA S.p.A.

CK Hutchison Networks Italia S.p.A. is dedicated to ensuring that its business activities are carried out with integrity, and in a fair and professional manner, while at the same time maintaining high ethical standards and respecting the local and international regulations. In this regard, the main instrument for implementing CK Hutchison Networks Italia S.p.A.’s business ethics is the Code of Conduct, that represents also a guideline for the behavior of all the people that works in the Company.
Within this context, CK Hutchison Networks Italia S.p.A. provided itself with the Organizational and Management Model (“Model 231”) drawn up in accordance with the provisions of Italian Legislative Decree No. 231 of 2001, which introduced the concept of administrative corporate liability for certain offences committed by employees and/or by third parties (e.g. Partners, Suppliers, Clients and other general stakeholders), in the interests or to the advantage of the company itself.
Then, all external and internal Company Partners have to adopt a behavior in line with the provisions of Italian Legislative Decree no. 231/2001 that you will find attached hereto.
Reporting of potential violations

In accordance with the Whistleblowing Regulation (Italian Law no. 197/2017, which amended art. 6 of Italian Legislative Decree 231/01), CK Hutchison Networks Italia S.p.A. defined the process for receiving and managing reports of behavior and/or conduct that may constitute a violation, even only potential, of the Code of Conduct, of company’s procedures and rules, and also of any laws and regulations currently in force. Regardless of the manner in which the report is submitted (from among the available reporting channels indicated below), CK Hutchison Networks Italia S.p.A. will guarantee the confidentiality and, if requested, anonymity of the reporting party, and will handle all the information relating to the case with the utmost confidentiality and in accordance with the current laws.
CK Hutchison Networks Italia S.p.A. will not tolerate retaliation, threats, or acts of discrimination against anyone who submits a report in good faith.

Reporting channels

CK Hutchison Networks Italia S.p.A. encourages anyone, whether employees or third parties (e.g. Business Partners, Suppliers, Customers, collaborators, and other general Stakeholders), to report, even anonymously, any potentially illegal behavior as specified above, in good faith and without fear of retaliation, using one or more of the following reporting channels:
- Reporting - Whistleblowing - web platform available by clicking HERE
- Helpline: 800 828 457 (toll free from landlines and mobile phones)
The “Reporting – Whistleblowing” Web Platform and the Helpline are managed by an external and independent company (Convercent), which is able to guarantee the confidentiality of the reporting party’s identity (as required by art. 2 paragraph 3 of Italian Law no. 197/2017) using computerized methods.

Reporting channels

CK Hutchison Networks Italia S.p.A. encourages anyone, whether employees or third parties (e.g. Business Partners, Suppliers, Customers, collaborators, and other general Stakeholders), to report, even anonymously, any potentially illegal behavior as specified above, in good faith and without fear of retaliation, using one or more of the following reporting channels:
- Reporting - Whistleblowing - web platform available by clicking HERE
- Helpline: 800 828 457 (toll free from landlines and mobile phones)
The “Reporting – Whistleblowing” Web Platform and the Helpline are managed by an external and independent company (Convercent), which is able to guarantee the confidentiality of the reporting party’s identity (as required by art. 2 paragraph 3 of Italian Law no. 197/2017) using computerized methods.

Any reports of violations or fraudulent circumvention of the principles and requirements of the Organization, Management and Control Model pursuant to Italian Legislative Decree no. 231/2001 (“Model 231”) can also be submitted via the Supervisory Bodies’ dedicated channels listed below:
E-mail: organismodivigilanzackh@ckhnetworks.it .

Postal address:
CK Hutchison Networks Italia S.p.A. - Organismo di Vigilanza 231/01
c/o Direzione Audit, Compliance 231 & Risk Management
Largo Metropolitana, 5 - 20017 Milano

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CK Hutchison Networks Italia SpA Antifraud and Anticorruption Guidelines
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CK Hutchison Networks Italia SpA Organisational Model
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Codice di Condotta Fornitori CK Hutchison Networks Italia SpA
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