In line with the company's transparency policy and with a view to corporate social responsibility, Alto adopted the Code of Ethics in 2019. The text inspired by the values ​​of correctness, legality, competence, regulates the activity of the company and of all the persons who are part of it and with whom it compares, by indicating behavioral norms.

The Code is an integral part of the Organization, Management and Control System pursuant to Legislative Decree 231/2001 which the company has adopted and which governs the administrative liability of legal persons, companies and associations.

Code of Ethics Integrated Policy

Alto Srl established channels for reporting violations and irregularities within the Phoenix Group's business activities. Since November 2023, a new platform has been in place which, by means of computerized methods and encryption tools, further guarantees the confidentiality of the identity of the reporting party, of the persons involved and of the content of the report and related documents. The procedure is in line with the regulatory changes introduced by Legislative Decree No. 24 of 10 March 2023 and concerns the protection of persons who report violations of EU law and national regulations.

The channel can be reached directly https://whistleblowing-phoenix.hawk-aml.com/Whistleblowing/home from the web platform of Whistleblowing managed by Cerved. The platform allows anyone (employees and collaborators, suppliers and any other person who has had business relations with the Company) to report any irregularities.

Whistleblowing presentation and Cerved manual