ORGANISATION, MANAGEMENT AND CONTROL MODEL PURSUANT TO ITALIAN LEGISLATIVE DECREE NO. 231/2001, UPDATED IN COMPLIANCE WITH ITALIAN LEGISLATIVE DECREE 24/2023

Pixartprinting S.p.A. (hereinafter also referred to as "Pixartprinting" or the “Company”), is a leading printing company that has been in the printing business for almost 30 years, performing online a service traditionally offered in physical shops.

The company provides customised online printing services, producing magazines, catalogues, labels, packaging, textile printing and more, its e-commerce is the largest web-to-print operation in Italy and one of the largest in Europe.

The Company has adopted an Organisation, Management and Control Model (hereinafter, the “Organisational Model”), drawn up in accordance with the provisions of Articles 6 and 7 of Legislative Decree No. 231 of 8 June 2001, as amended and supplemented (hereinafter, the “Italian Legislative Decree”). The Italian Legislative Decree regulates the liability of legal persons, companies and associations for administrative offences resulting from offences [1].

The Organisational Model adopted by Pixartprinting provides for specific rules and procedures in order to prevent the Company’s liability as a direct consequence of an offence committed by a natural person “to the advantage or in the interest” of the Company. More specifically, the Company is liable for offences committed by:

1. persons in a top position, such as persons holding the position of exponents, directors or managers of the company or of one of its organisational units with financial and functional autonomy, or persons exercising management or control over the company;
2. persons in a subordinate position, such as persons subject to the direction or supervision of one of the persons in a senior position (e.g., employees or independent contractors).

The Organisational Model aims to develop a corporate governance structure and a risk prevention system to prevent the commission of offences by managers, employees and external independent contractors. It should be noted that offences committed by partners or external independent contractors may also result in the liability of the Company; therefore, any behaviour of partners or external independent contractors in conflict with the Organisational Model and/or the Code of Ethics may constitute a breach of contract that will result in the termination of the contract and, if applicable, the request for compensation for any damages to the Company.

REPORTING PROCEDURE: “WHISTLEBLOWING”.

Within the context described above, there is also the regulation on Whistleblowing, recently updated by Italian Legislative Decree no. 24/2023, which has, among other things, defined how a report of unlawful conduct can be made to the Company, how it should be handled and what training the staff who will take charge of it should have. Pixartprinting, in order to comply with the new legislation, has set up an internal reporting channel capable of guaranteeing the confidentiality of the identity of the whistleblower, whether or not an employee, and of the person involved in the report, as well as the content of the report and the relevant documentation.

Reports, which can therefore also be received anonymously, can be made:

The management of these internal reporting channels is entrusted, depending also on the report made by the whistle-blower, to Pixartprinting’s Legal Department or to the third party provider of the platform delivery service.

Finally, thus also complying in this respect with the provision of Italian Legislative Decree no. 24/2023, the whistleblower has the option of reporting through the external reporting channel set up at ANAC as indicated at the link https://servizi.anticorruzione.it/segnalazioni/#!/#%2F

CODE OF ETHICS

Pixartprinting’s Code of Ethics, which incorporates the principles formulated by the Cimpress Code of Conduct, integrating and adapting them, identifies the reference corporate values (hereinafter also the “Code of Ethics”), highlighting all the rights, duties and responsibilities of all those who, in any capacity, operate within the Company or cooperate with it, whether they are employees, customers, suppliers, consultants, agents, business partners, public administration, civil servants, shareholders and, more generally, any other subject with whom contact is established.

The Code of Ethics is an integral and essential part of the Organisational Model and can be found in a special section of the Organisational Model, accessible to all employees.

The complete text of the Organisational Model and Code of Ethics, recently updated pursuant to Italian Legislative Decree No. 24/2023, is available at the following link: Code of Ethics