In performing their duties, PENTADA S.r.l. employees should always act lawfully, ethically, and in the best interests of PENTADA S.r.l. This Code of Business Conduct and Ethics (the "Code of Conduct") sets out basic guiding principles. Employees who are unsure whether their conduct or the conduct of their co-workers complies with the Code of Conduct should contact their manager or the Legal Department. Employees may also report any suspected non-compliance as provided in the Legal Department's reporting guidelines referred to in paragraph IX below.

I. Compliance with Laws, Rules and Regulations
       Employees must follow applicable laws, rules and regulations at all times. Employees with questions about the applicability or interpretation of any law, rule or regulation, should contact the Legal Department.

II. Conflicts of Interest
       In performing their duties, employees are expected to use their judgment to act, at all times and in all ways, in the best interests of PENTADA S.r.l. A "conflict of interest" exists when an employee's personal interest interferes with the best interests of PENTADA S.r.l. For example, a conflict of interest may occur when an employee or a family member receives a personal benefit because of the employee's position with PENTADA S.r.l. A conflict of interest may also arise from an employee's business or personal relationship with a customer, supplier, competitor, business partner, or other employee, if that relationship impairs the employee's objective business judgment.
       Employees should attempt to avoid conflicts of interest and employees who believe a conflict of interest may exist should promptly notify the Legal Department. The Legal Department will consider the facts and circumstances of the situation to decide whether corrective or mitigating action is appropriate.

III. Insider Trading Policy
Federal and state laws prohibit trading in securities by persons who have material information that is not generally known or available to the public.
       Employees of the Company may not: 
       * trade in stock or other securities while in possession of material non-public information
       pass on material non-public information to others without express authorisation by the Company or recommend to others that they trade in stock or other securities based on material non-public information.
       All employees are expected to review and follow the PENTADA S.r.l. guidelines. Certain employees must comply with trading windows and/or preclearance requirements when they trade PENTADA S.r.l. securities.

IV. Discrimination and Harassment
PENTADA S.r.l. provides equal opportunity in all aspects of employment and will not tolerate any illegal discrimination or harassment of any kind.

V. Health and Safety
PENTADA S.r.l. provides a clean, safe and healthy work environment. Each employee has responsibility for maintaining a safe and healthy workplace by following safety and health rules and practices and reporting accidents, injuries and unsafe conditions, procedures, or behaviours.
       Violence and threatening behaviour are not permitted. Employees must report to work in a condition to perform their duties, free from the influence of illegal drugs or alcohol.

VI. Price Fixing
Employees may not discuss prices or make any formal or informal agreement with any competitor regarding prices, discounts, business terms, or the market segments and channels in which the Company competes, where the purpose or result of such discussion or agreement would be inconsistent with applicable antitrust laws. If you have any questions about this section or the applicable antitrust laws, please contact the Legal Department.

VII. Bribery; Payments to Government Personnel
Employees may not bribe anyone for any reason, whether in dealings with governments or the private sector. Employees may not make illegal payments to government officials themselves or through a third party. Employees who are conducting business with the government officials of any country must contact the Legal Department for guidance on the law governing payments and gifts to governmental officials.

VIII. Record keeping, Reporting, and Financial Integrity
PENTADA S.r.l.'s books, records, accounts and financial statements must be maintained in appropriate detail, must properly reflect the Company's transactions and must conform both to applicable law and to the Company's system of internal controls. Furthermore, PENTADA S.r.l.’s public financial reports must contain full, fair, accurate, timely and understandable disclosure as required by law. The Company's financial, accounting and legal groups are responsible for procedures designed to assure proper internal and disclosure controls, and all employees should cooperate with these procedures.

IX. Questions; Reporting Violations
Employees should speak with anyone in their management chain or the Legal Department when they have a question about the application of the Code of Conduct or when in doubt about how to properly act in a particular situation.
       PENTADA S.r.l. Legal Department maintains reporting guidelines for employees who wish to report violations of this Code of Conduct. These guidelines include information on making reports to the Legal Department and/or to an independent third party. Please, see the reporting guidelines for information and instructions.
       PENTADA S.r.l. will not allow retaliation against an employee for reporting misconduct by others in good faith. Employees must cooperate in internal investigations of potential or alleged misconduct.
       Employees who violate the Code of Conduct will be subject to disciplinary action, including discharge.

X. Periodic Certification
The Legal Department will designate certain employees who, based on their level of responsibility or the nature of their work, will be required to certify periodically that they have read, understood and complied with the Code of Conduct.

XI. Board of Directors
With respect to their service on behalf of the Company, PENTADA S.r.l. Board of Directors must comply with the relevant provisions of this Code of Conduct, including conflicts of interest, insider trading and compliance with all applicable laws, rules and regulations.

XII. Waivers
Waivers of this Code of Conduct may be made only in the manner permitted by law.

Document last updated: December 2018.