Code of Ethics

1. INTRODUCTION

QLT is a law and tax firm established as a professional association offering legal and tax advice and assistance to Italian and foreign companies in all areas of law, with its own offices in Rome and Milan.

This Code of Ethics represents the framework of moral, professional and organizational principles that inspire the activity of QLT LAW & TAX – Studio Legale e Tributario Associato (the “Firm”). The Firm, active in legal and tax consulting, recognizes the importance of adopting a tool to guide transparent, responsible and ethical professional behavior.

This document constitutes an integral part of the principles of professional ethics set forth in the Forensic Code of Ethics and the Code of Ethics for Certified Public Accountants and Accounting Experts and applies to both the Rome and Milan offices, as well as to all the Firm’s activities, in Italy and abroad.

2. SCOPE AND ADDRESSEES

2.1. The purpose of the Code of Ethics is to define the fundamental values and rules of conduct to be adhered to by those acting in the name of or on behalf of the Firm, contributing to the protection of its reputation.

The addressees of the Code of Ethics are:

(i) the Partners, associates and trainees (“Professionals”);

(ii) the employees (“Employees”);

(iii) third parties who collaborate with the Firm in any capacity (“Third Parties”),

(Professionals, Employees and Third Parties collectively the “Addressees”)

Compliance with the Code of Ethics is binding on all Addressees.

2.2. The Code of Ethics is distributed to all Addressees and posted on the Firm’s website.

2.3. Addressees must:

– be familiar with the Code of Ethics and comply with its provisions;

– refrain from conduct contrary to its principles;

– request clarifications in case of doubts of interpretation;

– report any violations to the email address of the Managing Partner/s pro tempore in charge, or, in case the violation concerns the Managing Partner/s, to the email address of all other partners of the Firm;

– cooperate with internal references, as well as with external authorities in case of investigation.

2.4. Partners of the Firm, in addition to the above obligations:

– must represent a model of ethical conduct;

– promote the dissemination of the Code of Ethics among Professionals, especially their reference team, and Employees;

– prevent any form of retaliation against those who report illegal behavior.

3. VALUES AND GUIDING PRINCIPLES

1. All activities shall be carried out in accordance with applicable regulations and with the utmost respect for ethical principles.

2. Professionals are expected to act diligently, constantly update their skills, and ensure high performance.

3. Information processed must remain confidential and may not be disclosed or used for personal purposes. All documentation processed in the performance of assignments remains the property of the Firm.

4. It is forbidden to disclose to third parties information acquired in the course of professional activity or to use it after the termination of the professional relationship with the Firm, unless required by law, or requested by the authorities or expressly authorized.

5. Each Professional must act independently and loyally, avoiding situations that may generate conflicts of interest, even if only potential.

6. The Firm shall take appropriate measures to ensure compliance with anti-money laundering regulations, through internal procedures and training activities. Measures taken include, among others, the identification and verification of the identity of clients, the proper storage of information collected, the monitoring of transactions, and the timely reporting of any suspicious transactions to the competent bodies.

3.7. The Firm’s activities must be inspired by criteria of environmental sustainability, operating in accordance with the principles of environmental protection and conservation. Addressees are therefore required to carry out their activities with a sense of environmental responsibility, adopting behaviors aimed at containing the impact on the ecosystem and using the firm’s resources efficiently and consciously.

4. EXTERNAL RELATIONS

4.1. Relations with clients are based on trust, confidentiality, competence, and compliance with regulations and Codes of Ethics. Each assignment is preceded by adequate disclosure of objectives, operating methods and costs.

4.2. Relations with suppliers must be based on transparency, impartiality, competitiveness and mutual respect.

4.3. In relations with public entities or public officials, any form of corruption, undue pressure or behavior that could generate illicit advantages is prohibited.

4.4. It is forbidden to accept, offer or promise benefits that may influence the impartiality of decisions. Any irregularity must be reported immediately.

5. CONDUCT WITHIN THE FIRM

1. The Firm promotes a fair working environment that respects the dignity of individuals. Discrimination, abuse, harassment, and any form of harmful behavior are prohibited.

2. The IT tools provided by the Firm must be used exclusively for professional purposes and in such a way as to prevent any misuse. In particular, it is prohibited to use IT tools:

(i) for purposes contrary to the law, public order, or morality;

(ii) to damage, alter or destroy the Firm’s IT or telecommunications systems and/or those of third parties, as well as the data contained therein.

1. 3. Content shared online must comply with the principles of the Code of Ethics. It is forbidden to publish images, comments, or data relating to the Firm, its clients, or its activities without the authorization of the relevant Partner.

   4. All Addressees must refrain from communicating untruthful information about their role within the Firm in order to gain an advantage, including in terms of professional visibility.

   5. All Addressees are required to promptly disclose any personal or legal situations that may affect their relationship with the Firm or with clients.

6. VIOLATIONS

1. Violation of the provisions of the Code of Ethics constitutes a breach of contract and may result in disciplinary sanctions, termination of the working relationship and, in certain cases, reporting to the competent authorities.

This Code of Ethics was approved and implemented on May 5, 2025.