INTRODUCTION

The Code of Ethics is the document summarising the behaviour principles that executives, directors, managers, employees, and collaborators in whatever capacity, as well as the suppliers of SPAL Srl (hereinafter, the “Club”) must comply with in conducting business activities, in carrying out their work and, in general, in the internal and external relationships with the club itself, thus highlighting the set of rights, duties, and responsibilities of the Code’s recipients. It does not claim to be exhaustive.

This Code of Ethics (hereinafter, the “Code”) constitutes an integral part of the “Organisation, Management and Control Model” as set forth by art. 6 of Legislative Decree 231/2001 concerning the administrative liability of bodies and legal entities. It also constitutes fulfilment of the provision referred to in art. 7(5) of the Italian Football Federation (hereinafter, “FIGC”) statute.

By providing suitable information, prevention, and control tools, the Club ensures transparency of the conduct implemented, intervening, where necessary, to prevent any breaches of the Code. The Club will supervise the actual compliance with the Code itself both in internal relations and in relations between the Club and third parties, outside the sports system, as well as in relations between the club and third parties that are affiliated with, members of, or licensed by the FIGC or by the other soccer sports federations recognised by the Federation International de Football Association (hereinafter, “FIFA”).

This document was approved by the management bodies of the Club, which undertakes to ensure the widest dissemination thereof to all recipients and to the public in general, including via publication on their website (www.spalferrara.it).

RECIPIENTS OF THE CODE

The set of ethical principles, values, and behavioural rules articulated in this Code must inspire the activity of all those who operate, either within or outside, the Club’s sphere of action, including members of the corporate bodies, the management staff, employees, collaborators, consultants and commercial partners, as well as any other external collaborator of any kind and the external parties who operate in the name and/or on behalf of the Club.

All the parties to whom the rules of this Code apply are defined as “Recipients”, specifically:

1. The members of the Board of Directors, the President, the Vice President, the members of the Board of Statutory Auditors, the Managers and any other party in a senior position, meaning any person who is responsible for representing, administering, managing, or carrying out, both as to fact and law, the management of the Club, where they operate, both in Italy and overseas (the “Corporate Representatives”).
2. All staff employed by the Club, including fixed-term or part-time workers and workers similar to them;
3. All those who, directly or indirectly, permanently or temporarily, establish relationships with the Club or, in any case, operate in pursuit of its objectives;
4. External consultants and, in general, natural persons who maintain or would like to maintain commercial relationships with the Club on their own behalf or on behalf of the legal entities whom they represent; the sports professionals referred to in art. 2 of Law No 91 of 23 March 1981, as well as medical staff and members in general;
5. More generally, all those who, for any reason, operate within the Areas of Risk on behalf of and/or in the interests of the Club.

The Code is made available to all Recipients, who are obliged to comply with its provisions both in relationships with each other (so-called internal relationships) and in relationships with third parties (so-called external relationships), to actively contribute to its implementation and to report any gaps to the competent contact department.

1 GENERAL ETHICAL PRINCIPLES

The Code of Ethics, drawn up pursuant to art. 9(5) of the FIGC Statute and in accordance with Legislative Decree 231/2001 (hereinafter, the “Decree”), forms an integral part of the Club’s Organisation, Management and Control Model (hereinafter, the “Model”), and is intended to orient the operations, behaviour, and relationships - both internal and external - to the essential principles contained therein.

1.1 ENVIRONMENT

The Club promotes respecting and protecting the environment, actively undertaking to ensure full compliance with the current environmental legislation in carrying out its activities.
1.2 COMPETITION
The Club orients its own activity with respect for the rules of fair competition, which it believes to be an essential and indispensable value for the development of the corporate structure and for the needs of the public.

All the sports activities and behaviour of individual members, in managing relationships between themselves and the various components of the national and international soccer organisation, must turn on on this principle of fair competition.
1.3 IMPARTIALITY AND NON-DISCRIMINATION

The Club rejects, opposes, and sanctions any attitude, even only apparently discriminatory, which concerns nationality, state of health, age, sex, religion, religious, political, moral, or philosophical orientation, sexual preferences or attitudes, of its partners.
The Recipients, in conducting professional duties, must abide by the criterion of impartiality, avoiding the preference or assistance of people or solutions, if not on the basis of and in consideration of verifiable technical and professional assessments.

1.4 IMAGE OF THE CLUB

The Club considers its image and its reputation to be values that must be protected and developed, including through the full dissemination and sharing of, and compliance with, the ethical principals of sporting fairness and integrity as contained in this Code.
The Recipients must, therefore, abstain from any behaviour, both in public and in private, which may harm the Club’s image, and must exert themselves to ensure compliance with the same.

1.5 INTEGRITY

In relationships with the recipients, and with third parties in general, the Club undertakes to act with integrity and transparency, avoiding misleading information and behaviour such as to draw unlawful advantage from third parties’ disadvantage.

1.6 LEGALITY

Within their professional activity, the Club’s Directors, Employees, and external Collaborators are obliged to diligently comply with current legislation, the Code of Ethics, the regulations and internal rules.

1.7 RESPONSIBLITY

Each Recipient carries out their work and assignments with professional commitment, diligence, efficiency, and integrity, using the tools and time available to them in the best way possible and assuming the responsibilities connected to the commitments assumed.

1.8 CONFIDENTIALITY

The Club ensures the confidentiality of information in their possession and refrains from collecting and using sensitive data, except in the case of express and informed authorisation of the data controller and, in any case, in compliance with the current legal regulations. Directors, Employees, and external collaborators are banned from using confidential information for purposes unconnected with the performance of their duties.

1.9 COMPLIANCE WITH THE LAW AND REGULATIONS IN FORCE

The Recipients, in performing the duties of their appointment, are obliged to comply with current laws, reference sports regulations, and this Code. The Recipients must avoid putting themselves, in carrying out their respective activities, in any situation able to generate conflicts of interest, actual and/or potential, with the Club itself. A situation of “conflict of interest” refers to that in which an interest other than that of the Club and/or advantage of a natural person is pursued.

No behaviour contrary to the above-mentioned regulations and to this Code, even if grounded in the pursuit of a Club interest, may be justified, and will entail the Club’s adoption of sanctions.

1.10 RESPECT FOR THE PERSON

Staff are the company’s key resource: respect, growth and development opportunities, and recognition of personal merits represent its guidelines. Requests, accompanied by threats, violence, favours, or promises, aimed at inducing Directors, Employees, and Collaborators to act counter to the law and the Code of Ethics, are not tolerated and will, in fact, be sanctioned.

1.11 SAFETY

The physical and moral integrity of the Recipients is considered a priority for the Club.
The Club undertakes to comply with the regulations regarding occupational health and safety and updates thereto.
The Club guarantees its Employees, Collaborators, and users, in performing their professional services and during the holding of events, a safe and comfortable environment. In particular, we undertake to comply with all the obligations stipulated by Legislative Decree No 81 of 2008 as amended and supplemented.

1.12 TRANSPARENCY

The Directors, Employees, and Collaborators of the Club undertake to provide complete, correct, suitable, and timely information both externally (e.g. to the public administration) and internally. The information is provided clearly and simply and is usually provided via written communication.

1.13 RESPONSIBILITY, HONESTY, INTEGRITY

The people who work in the name and on behalf of the Club must conduct sports activities and perform their work with honesty, integrity, diligence, and fairness in relation to the other Recipients and third parties, which must include customers, suppliers, public administrations, private parties, opponents, and fans.

The Club also condemns any act or behaviour aimed at fraudulently obtaining registration in any sports competition, or membership of an athlete, in breach of or eluding the federal regulations and laws in force.

1.14 FAIR PLAY

The Club recognises the principles of Fair Play in conducting sports activities as essential.

1.14.1 THE OLYMPIC PRINCIPLES

The recipients of the Code of Ethics undertake to ensure, in carrying out professional activities and those that prepare or organise the former, rigorous compliance with the Olympic values. These values incorporate the concepts of friendship, respect for others, and sports integrity and comprise the fight against any practice that perverts or destroys the rules, against doping, against violence (both physical and verbal), against abuse and sexual harassment, against racial discrimination, against exploitation, against inequality of opportunities for young people, against corruption, and against the distorting commercialisation of sports values.

1.14.2 PRINCIPLES OF LEGALITY

The recipients of the Code of Ethics undertake to promote maximum active vigilance in order to prevent and report, without delay, any behaviour that harms sports fairness, any illegal activity, and any risk of criminal infiltration of the sports world.

1.14.3 PRINCIPLES OF FAIR COOPERATION

With fair cooperation in relation to public institutions, at every regional level, and sports institutions, and, in particular, in relation to the FIGC, the Recipients of the Code of Ethics undertake to encourage the effective and efficient application of laws, directives, regulations, or provisions issued by these institutions in all the legal and economic matters pertaining to sport and soccer in particular. The recipients also undertake to ensure full execution, without claims and protests - except legitimate complaints procedures - of decisions of the sports justice bodies.

1.14.4 PRINCIPLES OF FAIRNESS IN SPORT

The Recipients of the Code of Ethics undertake to behave, both in professional relationships and in those of an administrative nature, with maximum mutual fairness, complying with all the common practices of fair play in sports.
They undertake, therefore, to reject and denounce the practice of doping and that of sports betting, even if channelled via official operators, as factors that, even only hypothetically, can contribute to falsifying the results of sports events. In compliance with this purpose, the recipients may not participate in sports competitions or betting that relate to soccer matches, nor can they accept presents, gifts, benefits, or pressure that may influence the free formation of sports results expressed on the playing field.

1.14.5 PRINCIPLE OF PROTECTION OF THE PERSON

The recipients of the Code of Ethics undertake, in carrying out professional activities and those that prepare or organise the former, to comply, with scrupulous diligence and responsibility, with respect for the physical, moral, and cultural integrity of the person.
1.14.6 PRINCIPLES OF CORPORATE RESPONSIBLITY

In full awareness of the social and cultural function of sport in Italy - and in particular of soccer - the recipients of the Code of Ethics commit to responsible behaviours in relation to the sports community as a whole, with a particular focus on the world of supporter-spectators.

2 VALUE OF THE CODE

Any breach of the above-mentioned rules by their Recipients will constitute a breach of the obligations deriving from the employment or collaboration relationship, with every legal or contractual consequence.
The Club undertakes to provide for and impose, with consistency, impartiality, and uniformity, disciplinary sanctions that are proportional to the breaches of the Code and comply with the current legislative provisions regarding employment relationships.

2.1 REFERENCE BODY FOR APPLYING THE CODE

The reference body for applying the Code is the Guarantor of the Code, identified as the Club’s Supervisory Board (hereinafter, “OdV”) pursuant to Legislative Decree 231/2001, which has the task of examining reports of possible breaches and promoting the most appropriate investigations and checks, as well as proposing the imposition of the resulting sanctions to the competent body. The Guarantor also constitutes the point of reference for interpreting relevant aspects of the Code.

3 BEHAVIOURAL RULES

3.1 EMPLOYEE, COLLABORATOR, AND MEMBER RELATIONS

The Club recognises the centrality of human resources, as the main success factor of each business and sporting activity, within a framework of fairness and reciprocal trust between Club Representatives, employees, members, and collaborators.
The selection, training, management, and development of staff who are employed and those who are not (collaborators and contractors, etc.) are carried out without any discrimination, according to the criteria of merit, competence, and professionalism.

The sports professionals referred to in art. 2 of Law No 91 of 23 March 1981, are hired in compliance with the rules stipulated herein and in compliance with the federal regulations and current collective labour agreements. The purchase and assessment of members is carried out taking into account, in addition to the above, the policies of investment and payroll stipulated by the Club for each sports season, during the drafting of the budget.

3.1.1 ORGANISATIONAL FAIR PLAY

The Club undertakes to implement the policies of the FIGC aimed at arranging suitable sports and organisational structures, ensuring their staff include all the figures stipulated by the current regulatory sources, hereby including specialised medical staff, those in charge of equipment and occupational safety and in the stadiums, and various sports managers, limiting, as much as possible, the accumulation of responsibilities attributed to the same figures, in order to ensure the full operation and functionality of each department.

3.2 HEALTH, OCCUPATIONAL SAFETY, AND THE ENVIRONMENT

The Club works to protect, through prevention, the health and safety of employees, members, and collaborators, and ensures working conditions that respect the dignity of the individual and safe and healthy work environments, in full compliance with the current legislation regarding environmental protection and regarding the prevention of workplace injuries and the protection of workers. In the context of its corporate activities and relationships with third parties, it undertakes to adopt responsible attitudes in protecting the environment, acting in scrupulous compliance with the applicable regulations regarding environmental protection, as well as the limits defined by any authorisations and rules received from the competent bodies.

3.2.1 SPORTS EVENT SECURITY POLICIES

The Club also exerts itself, within the scope of its competences and responsibility, in ensuring the safety of all those who use its sports entertainment services.
The Club complies with the policies for sports event safety pursued by CONI (the Italian National Olympic Committee), FIFA, UEFA, and the general legal system and promotes and adopts all the measures and procedures within its purview, assigning the appropriate staff and resources for this purpose. In particular, the Club undertakes to assign resources and staff under the safety policy in the stadiums and sensitive neighbouring areas on the occasion of sports events. It scrupulously adopts the general safety measures stipulated by the Italian National Observatory on Sports Events as well as all the additional, special and occasional measures provided for on the occasion of particularly risky events, by the competent government authorities.

3.3 RELATIONSHIPS WITH THE FEDERAL BODIES AND PARTIES APPOINTED BY THEM
Relationships between the Club and sports institutions and authorities (by way of non- limiting example, FIFA, UEFA, FIGC, Lega Nazionale Professionisti [Italian National Professionals League] - Serie B, COVISOC [the Italian Supervisory Commission for Professional Soccer Clubs], CONI, and AIA [the Italian Referees’ Association]), as well as their representatives (employees, agents, representatives, referees, judges), are exclusively conducted by parties appointed by the Club itself, in compliance with the applicable state and sports law.

Without prejudice to defence and trade union rights, within the limits and forms permitted, of the decisions of the courts, the Recipients must refrain from attempting to influence, in any way, the decisions of the afore-mentioned bodies, in particular where they acting within their jurisdiction. The relationships must always be based on transparency and honesty, as well as the principles described in this Code of Ethics.

The Recipients must cooperate, if required, with the sports authorities and institutions in order to facilitate their activity. In particular, they have the obligation to present themselves before the Sports Justice bodies and produce all documents requested by the same or by the COVISOC. The Recipients also have the obligation to inform sports institutions of any illegal events they become aware of.

The Club rejects any form of corruption or attempt at corruption.

3.4 RELATIONSHIPS WITH OTHER CLUBS

The Club conducts relationships and business dealings with other national and international clubs according to the criteria of sports integrity and fairness, and in compliance with the national and international sports regulations, as well as current law.
3.5 RELATONSHIPS WITH THE PUBLIC ADMINISTRATION OR PARTIES APPOINTED BY A PUBLIC SERVICE

The Recipients must refrain from attempting to unduly influence in any way the decisions of the public administration or parties appointed by a public service. The Recipients must also refrain from attempting to obtain confidential information that may compromise the correct operations of the Club and of the public administration from the latter.

Where reasonably possible, relationships between the Recipients and the public administration must be documented in writing, so that, in the event, the nature and concrete methods for conducting these relationships may be checked.

The Recipients must refrain from offering money or gifts to managers, officials, or employees of the public administration or to their relations, both in Italy and overseas, unless this relates to gifts or benefits of moderate value that are part of normal courtesy.

The Recipients must refrain from accepting any object, service, or benefit to obtain a more favourable treatment in relation to any relationship held with the public administration.

If the Recipients make use of the services of a third party to represent them in relationships with the public administration, the Recipients must ensure that this third party undertakes to comply, in its operations, with the principles described in this Code.
3.6 PRESENTS, GIFTS, AND OTHER BENEFITS

No form of gift is allowed that can also only be interpreted as exceeding normal commercial and courtesy practices, or, in any case, intended to purchase favourable treatment in conducting any activity connected to the Club.
The Club is particularly sensitive in its relationship with different components of the FIGC and, in particular, with the Italian Referees’ Association (AIA), and requires Recipients, with special reference to members, to ensure their conduct complies with the precepts of this Code and exhibits maximum respect for federal regulations and current laws.

In any case, presents, gifts, and other benefits that are offered to the Recipients, unless of modest value, must be suitably authorised and documented to enable checks, according to existing internal practices or procedures.
3.7 RECIPIENT OBLIGATIONS

The Recipients must behave with fairness and integrity, in order to comply with the obligations included in the employment contract, those deriving from belonging to the sports system, via membership, and what the Code stipulates.
3.7.1 INFORMATION AND TRACEABILITY OF DOCUMENTATION

The Recipients must know and implement what is set forth internally in terms of information security in order to ensure its integrity, confidentiality, and availability.
The growing importance of IT technology requires ensuring the availability, safety, integrity, and maximum efficiency of Club data that is transmitted or stored electronically.

Each Recipient must store, in a way that is compatible with the Club’s procedures, suitable documentation for each operation carried out, in order to be able to proceed, at any time, with checks regarding the grounds and features of the operation in its authorisation, performance, registration, and verification steps.

3.7.2 CONFLICT OF INTEREST

It is the obligation of Recipients to avoid and prevent any situation that may lead to conflicts of interest, whether actual, potential, and/or apparent, among club activities, staff and/or affiliated persons, and to refrain from participating in adopting any decision or activity that may determine these situations, including when one’s participation may only engender mistrust in the impartiality and independence of the Club.

The Recipients who find themselves in a situation of conflict of interest, whether actual or potential, must report this to the Club and/or Guarantor of the Code.
3.7.3 USO CORRECT USE OF CLUB ASSETS
Each Recipient is responsible for the protection and correct use of Club assets, material or not, hereby including confidential information and IT resources and online ones, and has the obligation to punctually inform the structures responsible of any threat or event that may harm the Club.

In particular, each Recipient must:

• – operate with diligence to protect Club assets, through responsible behaviour consistent with the operating procedures prepared to regulate the use of the same;
• – avoid improper uses of Club assets for purposes contrary to mandatory legal provisions, the public order, or good conduct, as well as to commit or induce others to commit offences and/or, in any case, to incite racial intolerance, violence, and/or any breach of human rights.

3.7.4. ABUSE OF ALOCHOL OR DRUGS AND SMOKING BAN

All the Club’s people must personally contribute to promoting and maintaining a climate of mutual respect in the working environment, paying special attention to respecting others’ sensitivity. It is, therefore, expressly prohibited to:

• – keep, consume, offer, or sell in whatever capacity alcoholic substances, drugs, or substances with a similar effect, during work and in work places;
• – smoke in work places.

.3.7.5 MANAGEMENT

In all their activities, the sports managers must behave so as to ensure maximum professionalism and operating capacity and follow the rules of integrity, honesty, and morality, giving up sports appointments if they incur criminal sanctions. They must not incur sports sanctions for events connected to participating in bets on soccer sports events.

The absence of criminal charges and possession of subjective requirements, both direct and indirect, to obtain the anti-mafia certification must remain in place for the entirety of their appointment, role, club or sports position.

3.7.6 YOUTH SECTOR

The promotion of positive values in youth sports constitutes a priority for the Club, aware that setting a good example for youth is the most immediate form of education in mutual respect.

To this end, Recipients, and in particular parties who operate in the context of the youth sector, are required to comply with the principles, duties, and bans referred to in this Code.
The Recipients who scout and sell players, in particular for the youth sector, are required to operate in compliance with the current legislation, the guidelines defined by the Italian Football Federation (FIGC), and the Organisation, Management and Control Model pursuant to Legislative Decree 231/2001.
3.7.7 ATHLETES
Everyone must comply with the principle of solidarity, thus considering respect for sports values as more important than pursuing one’s own success, in the awareness that their behaviour contributes to reinforcing sport’s value.
Athletes must also commit to complying with current legislation, the protocols defined by the model according to Legislative Decree 231/2001, and what is set forth in the internal corporate regulations.
3.7.8 COACHES
Coaches must convey to their players values like respect, fair play, politeness, and integrity that go beyond the individual sports result and are the foundation of the sport. The behaviour of trainers, thus, must always be ethically correct in relation to all members: athletes, colleagues, referees, managers, parents, fans, and the media.
The trainers are taken as an example by youth as models of behaviour and must understand the strong influence that words and attitudes have in relation to the athletes who compose their team. For this reason, coaches must comply with the internal corporate regulations and the provisions of the model in accordance with Legislative Decree 231/2001.
3.7.9 MEDICAL STAFF
Medical staff must comply with the national and international regulations set forth regarding fighting doping and ensuring that the health, safety, and physical and psychological well-being of athletes is put before any other consideration. The medical staff must refrain from any conduct designed to prejudice the health of athletes and must not recommend prescriptions or administering pharmacological treatments aimed at altering their performance.
3.7.10 OPERATIONS STAFF
Operations staff comprise all the collaborators, both on a voluntary and professional basis, who lend their service in the administrative, organisational, and logistics areas to encourage the pursuit of its goals and good operation in the Club's daily operations. Each collaborator must be inspired by a strong sense of fairness, integrity, and respect in relation to whoever works for the club, as well as possessing values like respect, fair play, politeness, and moral integrity.

3.7.11 MEMBERS

It is forbidden, where not expressly authorised, to managers of the Club, partners, and members to carry out any activity relating to the transfer, contract sale, and membership of soccer players and coaches if not in the exclusive interest of the Club and in full compliance with the applicable sports regulations. In addition, it is forbidden to make use of and/or have contacts with banned or disqualified soccer player brokers or agents, or members.

In relationships with the sports professionals referred to in art. 2 of Law No 91 of 23 March 1981, as well as with soccer player brokers or agents, it is forbidden to sign agreements that are forbidden by the current sports regulations and/or to make payments, pay bonuses or benefits that are not legitimate or that breach the rules. All members are also obliged to respect the general principles and rules of conduct included in the “Members Conduct Regulations”, understood to be cited here in full.

3.7.12 FANS

In relationships with the fan base, the Club undertakes to promote loyal and responsible fans. To this end, it is forbidden to contribute, with financial support, the establishment and maintenance of groups, whether organised or not, of one’s own fans.
The Club undertakes to prevent the introduction and use in sports facilities of fireworks, tools/objects designed to offend, writing or symbols bearing obscene or offensive expressions or, in any case, those that incite violence and xenophobia.

The Club rejects and opposes any behaviour that, directly or indirectly, entails offence, denigration on the grounds of race, colour, religion, language, sex, nationality, origins, or constitutes ideological propaganda that is prohibited by law or, in any case, incites discriminatory behaviour.
3.8 BEHAVIOURAL RULES REGARDING SPORTS CRIMES, BETTTING, AND DOPING

I tesserati, dirigenti, dipendenti e collaboratori che operano per Members, managers, employees, and collaborators who work for SPAL SRL must refrain from undertaking acts aimed at altering the performance or result of sports competitions.
3.8.1 BAN ON BETTING
All those who work for SPAL SRL must refrain from making or even only facilitating, directly or via an intermediary, bets that concern the results of official competitions in which the Club participates.

More specifically:
It is prohibited for each member, manager, employee, collaborator, and consultant of the Club:

– to unlawfully promise or pay sums or assets in kind to any party for promoting or encouraging the interests of the Club or to condition, even indirectly, the regular performance of sports competitions;

– to agree to benefits of any kind or to put unlawful pressure on coaches, soccer players, or referees; in general, to undertake, using any means, acts directed at altering the performance or result of a match or competition in which the Club is engaged;

• – to make bets, directly or via third parties, on the outcome of Club competitions or of those of other teams competing;
• – to communicate to third parties confidential information whether of an economic or financial nature or relating to the technical and sports management of the team;
• – to use slot machines and to frequent places where you can bet online;
• – to bet on any other sport and any type of game of chance;
• – to frequent people who bet, either outside the club or within training camps, any intermediary who may be able to contact the world of betting.

3.8.2 FIGHT AGAINST DOPING

The Club is particularly sensitive to protecting the health of its athletes, both of the top team and of the youth sector; the Club bases all its sports activities on the correct use and administration of drugs, in compliance with the current laws regarding national and international doping. The Club rejects the use of any substance contrary to anti-doping regulations and verifies, with extreme attention, compliance with these principles on behalf of each of its members, considering it an essential, qualifying element in the employment relationship between the member and the Club.

All those who operate for the Club must comply with the rules, regulations, and standards, both national and international (World Anti-Doping Agency) regarding the fight against doping, hereby including the anti-doping sports rules issued by CONI and the FIGC supplements.

3.8.3 POLICIES FOR PREVENTING OFFENCES

If the Club and, on its behalf, the partners, directors, heads of the accounting and legal monitoring bodies, the sports managers, and all the employees and collaborators in any role become aware of any unlawful act, event, or conduct, which is relevant on the legal or statutory sports level, committed either by internal parties, including coaches, athletes, and members, or by external parties, are obliged to immediately denounce such, both to the federal prosecutor and to those in charge of police bodies and to the judiciary, depending on their relevance. The obligation to denounce also exists if there is knowledge of mere attempts to commit an offence not yet realised.

3.9 SELECTION OF AND CONTRACTUAL RELATIIONSHIPS WITH SUPPLIERS

The Club's relationships with suppliers and third parties in general, whether public or private, must be conducted in compliance with the law and respect for the principles of honesty, transparency, and verifiability, even if held via third parties.
Each contract will need to contain a special clause with which the supplier undertakes specific and thorough compliance with the principles of this Code, on pain of the Club’s right to terminate the relationship or act to receive compensation for any damages.

3.10 PROTECTION OF PERSONAL DATA

In carrying out its activity and in order to ensure the protection of personal data, the Club undertakes to process the same in compliance with the reference regulations and, in particular, in compliance with the following criteria: transparency in relation to the parties to which the data refer, lawfulness and correctness of processing, relevance of the processing to the purposes stated and pursued, security guarantee of data processed.

3.11 BAN ON POSSESSING PORNOGRAPHIC MATERIAL

It is absolutely forbidden to possess, in digital or paper format, at the Club’s premises or to disseminate via the Club’s website or publications edited or promoted by the Club, pornographic material or virtual images produced using images of minors under 18 years old.

3.12 MANAGEMENT OF MONEY, ASSETS, OR OTHER BENEFITS

It is forbidden to acquire, receive, or conceal or, in any case, act to enable the acquisition, receiving, or concealment of money or things derived from crime.
It is equally forbidden to transfer or substitute money, assets, or other benefits deriving from offences committed with criminal intent or to undertake, in relation to these, other transactions that hinder the identification of their illegal origins. Finally, it is forbidden to use money, assets, or other benefits deriving from an offence in economic or financial activities.

3.13 ACCOUNTING AND FINANCIAL MANAGEMENT

All management operations must be appropriately documented, in order to provide an accounting record that reflects the nature and substance of each transaction, according to the legal rules and regulations.
Each, when requested, is obliged to collaborate, in terms of the activities carried out, in the performance of control and audit activities legally attributed to the partners, corporate bodies, statutory auditors, or Supervisory and Control Authorities specifically stipulated by law and by the federal regulations so that true, correct, complete, and transparent information is provided to those parties.

3.13.1 FINANCIAL FAIR PLAY POLICIES

The Club complies with the policies of FIFA, the UEFA, the FIGC and promotes all measures aimed at a correct and generally balanced management of its financial assets, in order to ensure full operations, under these profiles, for the whole time it remains at the pertinent professional levels.

4 BEHAVIOURAL RULES IN EXTERNAL RELATIONSHIPS

4.1 CONTRIBUTIONS AND SPONSORSHIPS

The Club, where it identifies the opportunity, disburses contributions and sponsorships for cultural and sporting activities in compliance with the current regulations and principles contained in this Code.
In the selection of cultural and sports activities, the Club, its employees, and collaborators are obliged to avoid any form of conflict of interest (for example, familial relationships with parties concerned or links with bodies that may, for the tasks they perform, favour the Club’s activities in some way).

The Club refrains from distributing contributions or benefits of another kind to associations and/or groups of fans and supporters.
4.2 MASS MEDIA
Communication with the media has an important role in enhancing the Club’s image. Therefore, relationships between the Club and mass media are the sole responsibility of the bodies delegated to this, and must be carried out in line with the communication policies and tools defined by the bodies responsible, as well as the law, rules, and practices of professional conduct. Information provided to external parties is inspired by the criteria of truthfulness and transparency. It is absolutely forbidden to disseminate false information.

The Recipients are obliged not to provide information to the media, without having been specifically authorised to do so in advance by the competent departments.
4.3 PARTIES, TRADE UNION ORGANISATIONS, AND ASSOCIATIONS
The Club does not finance, neither in Italy nor overseas, political parties, their representatives or candidates, nor does it sponsor conferences or celebrations that have the sole purpose of political propaganda; it refrains from any direct or indirect pressure on political representatives (for example, via the granting of facilities, acceptance of suggestions for hiring, consultancy contracts).

5 IMPLEMENTATION OF THE CODE

5.1 PREVENTION

In compliance with current legislation and with a view to planning and managing the Club’s activities, aiming at efficiency, integrity, transparency, and quality, the Club adopts suitable organisational and management measures that are appropriate for preventing any illegal behaviour or, in any case, counter to the rules of this Code by any party who acts for the body.

5.2 REPORTS

Each breach of the principles and provisions contained in this Code by the Recipients must be promptly reported to the Code’s Guarantor.
It will be the task of the Code’s Guarantor to assess the reports and inform the management body, suggesting any sanctions to be applied.

In any case, the information and reports acquired, which are received in written form, are considered confidential and may not be disseminated, except in the cases stipulated by the current legislation.
5.3 SANCTIONS
Compliance with the rules contained in the Code must be considered an integral and essential part of the contractual obligations of Club employees pursuant to art. 2104 of the Italian Civil Code, as well as, with specific reference to members, in compliance with the current federal provisions. For this reason, the Club will require the inclusion of a specific clause in contracts already drawn up at the time of the dissemination of this Code, as well as in those to be signed in the future.

Any breaches of the Code will entail the application of sanctions in relation to the Club employees, managers, directors, and trade unions, including in accordance with the disciplinary system defined in the Organisation, Management and Control Model pursuant to Legislative Decree 231/2001.
The procedure for applying and imposing disciplinary sanctions is defined in the above-mentioned model, as part of the principles fixed by Law No 300/1970, as well as, for sports professionals, by the relevant collective agreement.

5.4 ENTRY INTO FORCE OF THE CODE AND UPDATES

This Code is adopted by resolution of 25 November 2016 and is effective immediately.
Each update, amendment, or revision of this Code must be approved by the management body.
A copy of this Code is provided to all Recipients and is available for consultation in electronic format on the Club’s website (www.salferrara.it), as well as in paper format in the offices of the same.

6 CONTACT DETAILS FOR THE CODE GUARANTOR

Whoever has information or a well founded suspicion of breaches or evasions of the principles contained in this Code or of the procedures defined in the Organisation, Management and Control Model, will report this to the Supervisory Board at the following address:
Supervisory Board Model 231

c/o S.P.A.L. S.r.l.
Via Copparo 142, 44123 Ferrara
or via e-mail: ODV231_CB@gmail.com
The OdV is not obliged to consider anonymous reports that appear, prima facie, to be irrelevant, without foundation, or not detailed.