Model 231, Code of Ethics and of Conduct

Introduction

M-I Stadio S.r.l. (hereinafter: the Company) was established to effectively manage the Meazza Stadium of San Siro (hereinafter “Stadium”) and related activities: the Company’s mission is therefore to manage and organize the Stadium in the best possible way, as a venue for sporting, musical, and cultural events, as well as a reference point for social life and gathering.

The Company, sensitive to the need to strengthen its corporate ethical culture and protect its position and image, as well as the expectations of its shareholders and employees, has deemed it appropriate to adopt its own Model 231, which represents the system of organizational, operational, and control rules governing the Company’s activities and conduct in order to prevent crimes and administrative offenses relevant to Legislative Decree 231/2001.

231/2001.

The Company also has a Code of Ethics, whose function is to provide guidelines and inspiration for the activities of the Company and all those who work with and for the Company, as well as to identify a set of rights and duties, the violation of which gives rise to specific responsibilities.

Finally, without prejudice to the legal autonomy of the Company, the Code expressly refers to and adopts the principles and values defined in the codes already adopted by its shareholders, with whom it shares the aspiration to spread and promote culture, ethics, and sports entertainment.

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