This Privacy Policy contains the information that regulates the processing of personal data of users (hereinafter referred to as the "User") who access and use the following sites, owned by Milor SpA, or by its subsidiaries, in particular: 

www.bronzallure.it
www.bronzallure.com
www.bronzallure.eu
www.etruscagioielli.com
www.albertm.it 
www.duomilor.it
www.milor.com
www.galleria-milano.com

each individually identified as "the Site") for its consultation and for the purchase of products for sale. ("Products").

Milor S.p.A. ("The Owner") is registered in the Business Register of the Milan Chamber of Commerce, C.F. / VAT No. 04362490155; the registered office is in Via dei Gracchi, 35 20146 Milan, email: privacy@milor.com.

This Privacy Policy is to be considered an integral and substantial part of the Terms of Use of each site and of the cookies policy.

The information contained in the Privacy Policy is extended in accordance with Article 13 of Legislative Decree 30 June 2003 no. 196 and succ. mod. - (the "Privacy Code") and Article 13 of EU Regulation 2016/679 ("GDPR") to all Users who access and use the Site and / or purchase the Products on the Site. This Policy refers only to the use of the Site and any other third party site, although referred to in any way within the Site.

Any changes will take effect immediately and will only apply to Users who use the Site after the date of such change. Consequently, we invite you to refer to it every time you go to our Site to get acquainted with its latest version available on the Site.

 

Version of 10 May 2018

The data entered by the User at the time of registration on the Site or the Site newsletter and at the time of forwarding each order, will be used for the purposes strictly related to the purpose indicated at the time of data collection and / or for the purposes indicated in this Privacy Policy. More precisely, for sending the newsletter and / or for executing the order request and all related services, such as payment and delivery. 

The User's personal data may also be used by the Data Controller and by third parties authorized by it to fulfill any accounting and tax obligations relating to the purchase of the Products and to complete all the activities strictly related and preparatory to the management of Site relations. -Customer. 

 In particular: carry out operations relating to our commercial relationship, that is to say concerning your subscription to the Services (in particular the verification of the veracity of your email), Orders, deliveries, invoices, accounting, the continuation of the "customer relationship "With a Member, and carrying out satisfaction surveys, handling complaints and after-sales service, refunds, specific commercial actions, returning Orders, exercising your right of withdrawal, managing outstanding receivables and disputes .

In the event that the User has given consent, such personal data may be used for other purposes relating to the sale of products on the Site: 
1. sending promotions, offers and suggestions on the Products for sale;
2. verification of User satisfaction;
3. sending promotional and / or advertising information relating to other activities of the Site and its Partners;
4. carry out market surveys and post-sales analyzes. 
5. propose commercial offers close to your geographical location, particularly in the context of offers that may include the "Collection in store" service;
6. the management of your comments on the Site and / or on the internet pages published by us and hosted on the internet sites of our Social Networks.

All User data collected will be processed exclusively and with due expertise by persons specifically appointed to this task and specially trained on the subject. The purposes of the processing are those for which the data were collected, mainly with electronic and IT tools.

The data will be stored on computer and paper supports, as well as on any other support deemed suitable and respectful of the security measures imposed by the applicable regulations. The data is stored in such a way as to make it possible to identify the User in the minimum time necessary to achieve the objectives for which they were collected and then processed and, in any case, always in compliance with the provisions of the law. 

Any damage caused by causes not directly attributable to the Owner such as inaccessibility of the Site, or viruses, damaged files, interruption of internet or telephone network connections, or other causes similar to the cases listed above are not attributable to the Owner.

Furthermore, the User is required to diligently and responsibly keep all personal information strictly connected to the Site, such as for example the access credentials to the Site, any order and shipping codes or other data. Any possible subtraction or improper use of this data, and the consequences deriving from these events, are the complete responsibility of the User.

The personal data requested by the Data Controller while browsing the Site may be mandatory or optional. Failure by the User to provide the mandatory data will result in the failure to fulfill the purpose for which they were requested. The compilation of optional data, on the other hand, is entirely subject to the discretion of the User who can choose whether to provide them or not. In this case, the refusal does not entail any consequence in the execution of the purposes indicated at the time of the request. 

The User is also responsible for constantly updating such data, in order to allow the Owner to exercise all services effectively and efficiently without incurring delays, errors or additional charges deriving from failure to update such data. 

In particular, the Data Controller collects the Data that you voluntarily declare starting from a collection form on the Site including socio-professional information (for example your profile, your surname, traditional name, names, gender, date of birth , godfather and / or delivery address, profession).

On the occasion of an Order, our bank lenders also collect and process Personal Data relating to your means of payment (credit card number, date and end of validity of the credit card, visual cryptogram - since it will not be stored, etc. ). For our part, we may process the partial number of your credit card consisting of the first six (6) numbers and the last four (4) numbers and the expiration date of your credit card as transmitted to us by your bank. Therefore, this payment identifier does not allow for banking transactions.

 We also collect information relating to the transaction made (transaction number, purchase details, etc.), or relating to the payment of invoices issued from or through the Site (payment methods, discounts granted, receipts, balances and non-payments, or relating to subscribed credits, amount and duration, etc.). 

 The Data Controller processes the Data relating to the control of the commercial relationship with you: product and / or service purchased, quantity, amount, frequency, delivery and / or billing address (s), telephone number, security code, and any other information relevant on delivery (tracking number, shipment location, etc.) history of purchases and services, product returns, correspondence and / or telephone exchanges between you and our after-sales service, etc.

The communication of the User's personal data to third parties is subject to compliance with the legal limits imposed and the purposes declared and envisaged in point 1. The third parties involved fall into the following categories:

1. those responsible for the warehouse, packaging, shipping, delivery and return services of the products;
2. the subjects appointed by the Owner for the administrative, contractual, accounting and legal management of the Site's activities;
3. credit institutions, insurance companies and the company (s) in charge of managing payments, including electronic ones;
4. the persons in charge of managing and maintaining the Site and all its functions;
5. any other subjects to whom the Data Controller has given the possibility of accessing the data, always in compliance with the provisions of the law or regulations.
6. affiliated, related, and offices associated with our Company, 

 Lastly, the User's personal data may be used for competitions and / or participation in prizes, for sending advertising and promotional material concerning the Site and the Owner's Partners, only with the explicit and voluntary consent expressed by the User. .

In cases where the processing of data provides for the explicit and voluntary consent of the User, it will be collected in a specific way with clarification of the individual purposes pursued. It is specified that Article 6 of the GDPR provides for cases in which the processing of data does not require the express authorization of the User, such as for the fulfillment of legal or contractual obligations undertaken towards the User.

The User has the right to request confirmation of the existence of personal data concerning him at any time, pursuant to articles 12 and following of the GDPR.

In compliance in particular with the Personal Data Regulation, you benefit from the following Specific Rights of:

access (Article 15 of the GDPR), 
b. rectification (Article 16 of the GDPR), 
c. cancellation (Article 17 of the GDPR), 
d. limitation of processing (Article 18 of the GDPR) 
And. transferability (Article 20 of the GDPR) 
f. opposition (Articles 21 and 22 of the GDPR) 
g. post-mortem directives (Law no. 78-17 of 6 January 1978 relating to information technology, files and freedoms);

You have the opportunity to obtain confirmation from the Data Controller that the data concerning you are or are not processed and, if they are, access to such data and the following information:

1. the purposes of the processing;
2. the categories of data;
3. the recipients or categories of recipients to whom the data are or will be communicated;
4. when possible, the data retention period envisaged or, when this is not possible, the criteria used to determine duration dates;
5. the existence of the right to ask the Data Controller to rectify or delete data, or to limit the processing of your data, or the right to object to such processing;
6. when the data are not collected by you, any information available regarding their source;
7. when data is transferred to a third country or to an international organization, you have the right to be informed of the appropriate guarantees relating to such transfer.

You have the possibility to obtain from the Data Controller, as soon as possible, the correction of the data concerning you and which are inaccurate. You also have the option of requesting incomplete data to be completed, even if a supplementary declaration is required.

You have the possibility to obtain from the Data Controller the cancellation, as soon as possible, of data concerning you when for one of the following reasons:

to. the data are no longer necessary in light of the purposes for which they were collected or otherwise processed by the Data Controller,
b. you have withdrawn your consent to the processing of this data and there is no other legal basis for the processing;
c. exercise your right to object under the conditions set out below
d. there is no legitimate imperative reason for the processing;
And. the data have been subject to unlawful processing;
f. the data must be deleted to comply with a legal obligation;
g. the data was provided by a child.

You have the possibility to obtain from the Data Controller the limitation of the processing of your data in application of one of the following reasons:

to. the Data Controller verifies the accuracy of the data following your dispute of the accuracy of the data.
b. the processing is unlawful and you oppose the deletion of the data, demanding in its place the limitation of their use;
c. the Data Controller no longer needs the data for the purposes of their processing but they are still necessary for the ascertainment, exercise and / or defense of rights in justice;
d. you have opposed the processing in the conditions set out below and the Data Controller checks to find out if the legitimate reasons pursued prevail over the reasons given.

You have the possibility to receive from the Data Controller the data concerning you in a structured format, currently used and readable on a device when:

1. Data processing is based on consent and or on a contract, e
2. The processing is carried out with the help of automated procedures.

When you exercise your right to portability, you have the right to obtain that the data be transmitted directly by the Data Controller to a data processor that you can designate when technically possible.

You have the right to object at any time, for reasons pertaining to your particular situation, to a processing of data concerning you based on the legitimate interest of the Data Controller.In this case, it will no longer process the data, unless it demonstrates that legitimate reasons exist. and compelling for processing that prevail over your interests and your rights and freedoms, or may keep them for the purpose of ascertaining, exercising or defending rights in justice.

When the data is processed for prospecting purposes, you can object to the processing of this data at any time.

Finally, the User has the right to object, in whole or in part for legitimate reasons, to the processing of personal data concerning him, even if pertinent to the purpose of the collection as well as to the processing of personal data concerning him for the purpose of sending advertising material. or direct sales or for carrying out market research or commercial communication.

To exercise the rights, the User can contact the following addresses: Tony S.r.l. - Via Carducci 32, 2012 Milan - email: privacy@milor.it 

The data controller of the personal data of the Users who use the Site is Milor S.p.A. - Via dei Gracchi 35, 20146 Milan. For the exercise of their rights and for any further information regarding the processing of data, the User can contact the Data Controller at the following addresses: Milor S.p.A. - Via dei Gracchi 35, 20146 Milan - email: privacy@milor.it.

Your Personal Data are kept on an active basis for a period of three (3) years starting from your last activity on the Site or on an electronic communication medium (particularly an e-mail message) or, after this deadline, your profile. it is considered "inactive" and will be automatically deactivated. It is therefore up to you to create a new one for any new Orders.

Your Personal Data in connection with an Order are kept for a duration of three (3) years starting from an Order. They remain accessible to you and us, particularly after your account has been created to allow you and us to have a complete history of your Orders. We can cancel them at any time upon simple request from you.

However, at the end of the aforementioned periods, and where applicable, starting from your request for deletion, your Personal Data may be subject to intermediate archiving to meet our legal, accounting and tax obligations.

The Site is present on Social networks. For more information on the protection of your data while browsing these social networks, please consult their respective privacy policies.

To allow us to register or connect to our site easier, you may have the opportunity to log into our site via a social network. Just click on the dedicated button in order to automatically pre-fill your registration form on the Site based on the information you have already provided to the Social network. For our part and as a recipient, we can collect information when you browse the pages of our Social networks or use their authentication features.

A "cookie" is a connection marker that designates a text file that can be recorded, based on your choices, in a dedicated space on the hard disk of your Terminal, when consulting the Site. A cookie file allows those who issues to identify the Terminal in which it is registered, for the duration of validity or registration of the cookie, for which it must be considered as a Personal Data. When you connect to our Site, we may be induced, based on your choices, to install different Cookies in your Terminal that allow you to recognize the browser of your Terminal during the validity period of the Cookie in question. No personal data of users is acquired by the Site on purpose. Cookies are not used to transmit information of a personal nature, nor are so-called c.d. persistent cookies of any kind, or systems for tracking users. The use of so-called session cookies (which are not stored permanently on the user's computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow safe browsing and efficient site. The so-called Session cookies used on this site avoid the use of other IT techniques that are potentially detrimental to the confidentiality of users' browsing and do not allow the acquisition of the user's personal identification data.

The Code of Ethics represents the identity card of an organization; it expresses the guidelines of conduct that must inspire the behavior of its members and is the main means of disseminating the culture of ethics within the company. The diffusion of the Code of Ethics has increased over the last few years, also by virtue of specific legal provisions which, especially at the international level, have led companies and other organizations to adopt it.

As a result of the globalization of markets, the concrete need to introduce and clarify ethical and social rules in economic models that allow profit and value creation objectives to coexist with compliance with requests and interests of the subjects involved in the business activity, not only in national and international relations but also in the corporate spheres (either because the expectations and interests, albeit legitimate, of the various subjects involved - Shareholders, Collaborators, Suppliers, Customers, Business Partners etc. - they can be in contrast with each other, either because in some cases there is a risk that the actual behaviors do not correspond at all to the proclaimed principles).

In the Italian panorama, the importance of having a tool such as the Code of Ethics is emphasized, among other things, by the provision of a specific liability of entities as a result of the commission of crimes pursuant to Legislative Decree no. 8 June 2001 231.
In this context, the companies belonging to the Milor group (the "Group") have always been committed to the application of rigorous principles observed in the performance of the various activities and have always been characterized by the seriousness, reliability and professionalism of the work of their Management , of its Employees and Collaborators, so as to acquire over the years a consolidated reputation also appreciated at an international level.

In order to pursue objectives of continuous improvement, Milor has deemed it appropriate to adopt and issue this Code of Ethics which sets out the corporate principles and values it has pursued over the years, highlighting rules of conduct whose observance - by all those who, in any capacity, they operate in the name and on behalf of the companies of the Group - it is essential to maintain and improve the regular functioning, the reliability of the company processes and the image of the Group itself.

The operations and conduct of all recipients of this Code of Ethics must be referred to these principles and rules, both in internal professional relationships and in relations with subjects outside the Group.

The Group recognizes the importance of ethical and social responsibility in the conduct of business and company activities and is committed to respecting the legitimate interests of Shareholders, Directors, Employees, Collaborators, Customers, Suppliers and Business Partners.

The companies of the Group therefore undertake to:

- maintain consistency with the policies always adopted in terms of fairness, transparency, trust and cooperation in the conduct of business;
- maintain an active role with respect to the market, economic development and technological progress of the sectors in which it operates;
- pursue a solid and sustainable value from an economic, financial and social point of view, built on the trust of Customers, on the motivation of Collaborators and on a responsible and constructive relationship with the territory;
－ Continuously improve the quality of the products and services offered to the Customer, increase the satisfaction of the latter through effective and fair competition on the market, in full and absolute compliance with the law and regulations in force in the countries in which it operates;
- raise awareness and involve Suppliers in a pro-active role, especially with regard to compliance with laws and regulations in the supply of goods and services and with regard to transparency and contributes, among other things, to spontaneous compliance by each Employee and Collaborator.
- Promote the personal and professional development of its Collaborators and motivate them to a sense of belonging and the search for continuous improvement of efficiency and effectiveness in order to increase corporate and personal satisfaction and well-being.

At the same time, it requires all Employees belonging to Group companies and all those who cooperate in the exercise of business activities to comply with company rules and the provisions established in this Code of Ethics.

In fact, the achievement of these objectives can only take place through the constant and active participation of all the subjects involved in the business activities of the companies of the Group and the full awareness, on the part of the same, that these goals must be achieved in compliance with those values. reference and rules of conduct which, by means of this Code of Ethics, are made explicit.

The rules contained in this Code of Ethics and the principles of conduct for the conduct of business and interpersonal relationships must therefore not appear to the recipient of this document as "discounted", but as a tool for reflection on the values recalled: a personal adherence to these values contribute, among other things, to the spontaneous respect on the part of every Employee and Collaborator.

The reference values and rules of conduct set out in the Code of Ethics are binding for all Group companies, for their Directors, Employees and Third Parties who in any capacity operate in the interest of the Group; the latter include Agents, Technical Assistance, Suppliers, Distributors, Developers, Consultants and Collaborators in general (hereinafter "Collaborators"). In particular, the Directors are required to be inspired by these values and rules of conduct in setting the objectives of the companies in the companies of the Group, in proposing investments and carrying out projects, as well as in any decision or action relating to the management of the companies.

Employees with executive qualifications, in concretely implementing the management activities of the companies of the Group, must be inspired by the same values and rules of conduct both within the Group, thus strengthening cohesion and the spirit of mutual collaboration, and in towards third parties who come into contact with the Group itself.

All Employees are required to comply, in carrying out their functions and responsibilities, with the principles and rules of conduct contained in the Code of Ethics, with company procedures, regulations and policies.

All Employees are also called upon to demand compliance with the principles and rules contained in this Code of Ethics also by independent third-party Collaborators who, in any capacity, operate in the interest of the Group. They undertake to make the Collaborators aware of the content of this Code of Ethics and to instruct them to comply with the rules contained therein.

Group Collaborators are required to adapt their behavior to the provisions of the Code, to company procedures and regulations.

Compliance with Laws and Regulations
The companies of the Group recognize compliance with the laws and regulations in force in all the countries in which they operate as an essential principle. The Directors, Employees and Collaborators who are involved in various capacities in the Group's business activities are therefore required to carry out their activities in a context of maximum transparency and in full compliance with the laws and regulations in force in the place and in the time in which they operate. They therefore undertake to have the best possible knowledge of the applicable regulations relating to their business and of the responsibilities deriving from their violation. In no case can the pursuit of the Group's interest justify an action that does not comply with the laws and regulations.

Integrity
Moral integrity is a constant duty of all those who work in the name and / or on behalf of the companies of the Group. All recipients of this Code of Ethics are required to pursue the objectives with honesty, fairness and responsibility and to maintain a conduct based on compliance with the rules, laws and professional ethics.

Transparency and completeness of information
The companies of the Group promote transparency in communications, in formal agreements and in the criteria that underlie the conduct followed in order to allow autonomous and informed choices by the parties involved. All recipients of this Code of Ethics are required to comply with the principles of truthfulness, correctness, completeness, accuracy and transparency of information and to communicate the image of the Group with clarity and diligence in all its internal and external relations.

Value of the person
The companies of the Group promote respect for the physical, moral and cultural integrity of the person; they guarantee working conditions that respect individual dignity and safe working environments. All recipients of this Code of Ethics are called upon to promote listening and dialogue as levers for improvement and continuous stimulus for the search for the solutions proposed not only in relations with customers but also in relations with their collaborators and colleagues in the respect for the professionalism and competence of each one.

Equity and equal opportunities
The companies of the Group undertake to avoid any discrimination in personal conduct and to respect the differences of gender, age, race, religion, political or trade union membership, language or different skills. All recipients of this Code of Ethics are called to operate taking into account the concrete circumstances; not taking discriminatory and opportunistic behaviors but helping to bring out the potential of each one.

Correctness
In the conduct of any activity, situations must be avoided in which the subjects involved in the transactions are, or may even appear, in conflict of interest.

Relations with control bodies
Relations with control bodies are inspired by the principles of transparency, completeness, truthfulness and correctness of information.
The information that, according to current legislation, must be communicated to the control bodies cannot be withheld or distorted.

Confidentiality
Milor ensures the confidentiality of the information in its possession and refrains from seeking confidential data, except in the case of express and informed authorization in accordance with the legal regulations in force. Group collaborators are required not to use confidential information for purposes not connected with the performance of their job duties.

Market freedom
Milor conforms its business to safeguarding the principles of competition and market freedom and, compatibly with the managerial autonomy of the individual subsidiaries, directs the Group's business to these principles.

Milor's Code of Ethics is aimed at all Group companies, their Directors, Employees and Collaborators, regardless of the specific productive and / or commercial organizational realities and explicit rules of conduct on which it calls for compliance by all recipients . The Directors, Managers, Employees and Collaborators who have contractual relationships with the Group in any capacity, are required to observe and enforce these principles within the scope of their functions and responsibilities, as well as to collaborate in the preparation of adequate procedures aimed at safeguard the interests of the Group.

In compliance with the values set out above, the Group recognizes human resources as an indispensable element for successfully competing on the market and for achieving corporate objectives, as well as the importance of establishing relationships with them based on loyalty and mutual trust.

The companies of the Group must ensure that the selection, classification and career path of company personnel, as well as the choice of Employees and Collaborators in various capacities respond exclusively, without any discrimination, to objective considerations of the professional and personal characteristics necessary for the execution of the work to be performed and the skills demonstrated in carrying it out. The companies of the Group must refuse any discriminatory behavior with regard to access to work, the attribution of qualifications and duties, career progression or the assignment of positions.

Resource selection and management
In light of the above, the company policies for the selection, remuneration and training of Employees and Collaborators must be based on criteria of professionalism, seriousness, competence and merit. In particular, the functions in charge must ensure that:

- the resources acquired correspond to the profiles actually necessary for company needs, avoiding favoritism and facilitations of any kind in compliance with equal opportunities and without any discrimination on the private sphere and on the opinions of candidates;
- Employees and fair and consistent behavior towards Collaborators, abuses and discrimination based on sex, race, religion, political affiliation and preventing favoritism, trade union, language, age or different abilities are maintained;
- equity of treatment and equal opportunities are guaranteed in the assignment of roles or tasks, considering mobility to different job positions as an element to promote professional growth.

Professional development and training of resources
The companies of the Group undertake to contribute to the training and professional growth of their Employees and Collaborators by offering them, periodically, opportunities both for mutual knowledge and information on their respective work experiences, and for other training interventions, and this in order to promote the growth and to allow them to develop their professional competence within the Group.

For this reason, the Executives and Department Managers are required to pay the utmost attention to enhancing and increasing the professionalism of their colleagues and Collaborators by creating the conditions for the development of their skills and the realization of their potential. In particular, the functions in charge must ensure that:

- the conditions necessary to develop the skills, abilities and talent of each are maintained in compliance with the company policies of equal opportunities;
- systems for assessing behavior, skills, knowledge and potential are maintained according to criteria of transparency and meritocracy;
- the possibility of expressing one's individuality in work is recognized, valuing the diversity and specificity of each one, as an essential contribution to the growth of the Group;
- the conditions are maintained that enable everyone to perform their role in the best possible way by encouraging the constant improvement of the level of competence and developing the ability to work as a team to contribute to the achievement of business objectives;
- training that is also attentive to individual needs is proposed, evaluated and developed in the definition of training courses.

Work environment
All Employees and Collaborators must be treated in strict compliance with the principles set out in this Code of Ethics and in the context of a climate that favors communication and cooperation as much as possible, among themselves and with superiors and subordinates, with a view to a common and shared objective of growth and consolidation of the spirit of belonging to the Group. In particular, the top management, executives, employees and collaborators who work in various capacities on behalf and / or in the name of the companies of the Group must:

- base their interpersonal and professional relationships on criteria and behaviors of correctness, loyalty and mutual respect;
- promote and support respect for the personality of each colleague and Collaborator as a fundamental element for the development of a work environment permeated by mutual trust and the contribution of each one;
- undertake to create a work environment that guarantees, to all those who interact with the companies of the Group in any capacity, conditions that respect personal dignity and in which the characteristics of individuals cannot give rise to discrimination or conditioning;
- aiming to create a work environment that is always stimulating and rewarding and which therefore favors the development of everyone's potential.

 

The most rigorous accounting transparency of each company in the Group is, at any time and under any circumstances, a priority requirement of the Group itself. The procurement and disbursement of financial resources, as well as their administration and control, must always comply with the Group's approval and authorization procedures.

The Directors, Employees, Collaborators and all those who have relations with the Group in any capacity, must behave strictly correct, transparent and collaborative in compliance with the law and company procedures in all activities aimed at preparing the financial statements and other corporate communications. In particular, the following is mandatory:

- everyone is required to strictly observe the procedures envisaged and to provide the utmost cooperation so that the management facts are presented correctly and promptly in the company accounts;
- each within the sphere of their respective competences and functions, must comply with the most rigorous principles of transparency, correctness and truthfulness in the preparation of documents and accounting data, as well as any registration relating to the administration;
- in the case of economic and equity elements based on valuations, the related recording must be made by clearly illustrating, in the relative documentation, the criteria that guided the determination of the value of the asset;
- the documentation supporting each accounting operation must be adequate, truthful, clear and complete; must be kept in the records, in such a way as to allow at any time the control over the characteristics of the operation, the reasons, and the precise identification of who, in the various phases, authorized, carried out, recorded and verified the operation itself; competences must be clearly defined and known within the organization;
- the related accounting entry must clearly, completely and truthfully reflect what is described in the supporting documentation;
- the supporting documentation must be easily available and filed according to appropriate criteria that allow easy consultation by both internal and external bodies authorized to control.

Correctness of financial flows
Any operation that may involve the slightest possibility of involvement of the Company in cases of receiving stolen goods, money laundering, use of goods or money of illicit origin is strictly prohibited. Financial flows must be managed by ensuring complete traceability of operations, keeping adequate documentation and always within the limits of the responsibilities assigned to each. To this end, it is necessary to comply with the following principles regarding the documentation and retention of records:
- all payments and other transfers made by or in favor of the Company must be accurately and fully recorded in the company accounting systems;
-. all payments must be made only to subjects and for activities contractually formalized and / or approved by the Company.

The Company implements the necessary checks to verify the authenticity of cash collected and used in the context of company activities. Recipients are required to use the utmost diligence and attention in the management of cash to ensure that counterfeit money is not collected or spent. The Company is committed to ensuring that the gold used for the production of its jewelery items does not come from world geographic areas involved in war conflicts generated by economic interests for the control of the extraction of precious metals. It also confirms that it is committed to the responsible sourcing of gold.

To this end, our commitment is to ensure compliance with the Dodd Frank Act and to purchase gold only from banks, metal banks or refineries that are included in the LBMA Good Delivery List or that are certified by the RJC (Responsible Jewelery Council) organization.

In compliance with current legislation, the companies of the Group undertake to guarantee the protection of privacy with regard to information relating to the private sphere and the opinions of each of their Employees and of those who interact with the Group. Employees and Collaborators acting in the name or on behalf of the companies of the Group are required to process personal data in full compliance with current legislation for the protection of privacy, in accordance with the directives given to them. In particular, it is mandatory to:

- acquire and process only the data necessary and directly connected to its functions;
- respect the confidential and confidential nature of the information;
- acquire and process data for specific, explicit and legitimate purposes;
- acquire and process data that are relevant, exact, complete and not excessive in relation to the purposes for which they were collected and subsequently processed, ensuring their due updating;
- keep said data in such a way as to prevent unrelated third parties from gaining knowledge of it;
- communicate and disclose the data only within the established procedures or with the prior authorization of the responsible managers;
- keep the data in a form that allows the identification of the data subject for a period of time not exceeding that necessary for the purposes for which they were collected and subsequently processed.

The Management, Employees or Collaborators in charge of processing personal data must take all appropriate measures to avoid the risk of destruction or loss, even accidental, of the aforementioned data, of unauthorized access to them or of unauthorized or unauthorized processing. in accordance with the purposes of the collection; these measures are identified and periodically updated within the Group companies.

The companies of the Group aim to maintain the highest levels of hygiene and safety and to guarantee the necessary prevention measures against accidents and illnesses in the workplace. Everyone must help keep the work environment in which they work healthy and safe and ensure the safety of their colleagues and collaborators of various capacities.

Each company function must do everything possible to always have full knowledge, for the sector under its responsibility, of the rights and obligations of the Group deriving from legal provisions, contracts or relations with the Public Administration and must not engage in any behavior that may harm, in any way, the interests of the Group.

All Employees and Collaborators who work on behalf or in the name of the Group companies are strictly prohibited from disclosing to third parties information not known to the public regarding projects, acquisitions, mergers, commercial strategies and more generally information regarding companies in the Group of which they have become aware or whose dissemination may, in any case, prejudice the interests of the Group itself.

Each subject has the responsibility of guarding, conserving and defending the assets and resources of the Group entrusted to him in the context of his business and is obliged to use them in a proper and compliant manner, preventing any improper use.

In order to protect the integrity of the corporate assets, it is in particular prohibited, outside the cases permitted by law, to:

- return contributions in any form or release the shareholders from the obligation to make them;
- distribute profits not actually earned or destined by law to reserves, or to reserves that cannot be distributed by law, purchase or subscribe shares or
company shares;
- carry out reductions in the share capital, mergers or demergers in violation of the rules for the protection of creditors; to sign or fictitiously increase the share capital; satisfy, in the event of liquidation, the claims of the shareholders to the detriment of the corporate creditors.

This context includes all those relationships, relating to the activities of the companies of the Group, entertained with public officials or with persons in charge of public service who work on behalf of the Public Administration or national and foreign legislative bodies, community institutions, public organizations of any foreign state.

Relations with governments and public institutions are reserved for corporate functions authorized to establish and manage such relationships on the basis of the provisions of the service orders and pro-tempore procedures in force. These relationships must be undertaken and managed in full and rigorous compliance with the laws and regulations in force, the rules and principles set out in the Code of Ethics and the internal reference procedures.

Attention and care must be paid in relations with the above-mentioned subjects, in particular in the areas relating to: tenders, contracts, authorizations, licenses, concessions, requests and / or management and use of loans, however denominated of public origin (national or community), management of orders, relations with supervisory authorities or other independent authorities, social security institutions, bodies responsible for the collection of taxes, civil, criminal or administrative proceedings. Attention and care must also be paid to those sectors which, although they do not involve direct relationships aimed at concluding business with the Public Administration, are considered to support business activities such as the management of financial flows and the management and security of IT data.

The aforementioned operations and the related management of financial resources must be undertaken in due compliance with the laws, the principles of the Code of Ethics and in full compliance with internal procedures. In particular, it is expressly forbidden to:

- accept, give or promise, either directly, indirectly, or through a third party, money, gifts, goods, services, services or favors to public officials - or to subjects linked to them by kinship or affinity relationships - for the purpose to promote and favor their own interests or the interests of the companies of the Group, or even to compensate or repay for an act of their office, or to achieve the execution of an act
contrary to the duties of their office;
- to receive, offer or promise gifts or other forms of gifts to public officials or to persons linked to them by kinship or affinity - when such gifts, in consideration of their value, exceed normal commercial and courtesy practices or in any case are positioned in the outside of what is expected
by internal company protocols;
- hire staff, assign agency, consultancy or other assignments, in the event that the hiring or the assignment are - or may appear - aimed at an exchange of favors with subjects belonging to, or previously belonging to, the Public
Administration;
recognize remuneration in favor of external Collaborators who are not adequately justified by the type of assignment to be carried out and by the practices in force in the local area;
- submit untruthful statements or other types of documentation to public bodies in order to influence independence of judgment;
- submit untruthful declarations or documentation of any other type to national or EU public bodies in order to obtain public grants, contributions or subsidized loans;
- allocate sums received from national or EU public bodies by way of grants, contributions or loans for purposes other than those for which they were intended;
- alter the functioning of an IT or telematic system or manipulate the data contained therein in order to obtain an unfair profit causing damage to the Public Administration.

In relations with the Public Administration, it is always necessary to operate in compliance with the law, with the express prohibition of engaging in conduct which, in order to bring advantages to the Group, are such as to integrate offenses.

Relations with suppliers
The Directors, Employees and Collaborators of the Group companies are required to guarantee equal opportunities in the selection of Suppliers, taking into account their compatibility and adequacy to the size and needs of the Group. In particular, the functions responsible for selecting independent third parties such as consultants, agents, suppliers of goods, goods and services must ensure that:

- are selected on the basis of evaluations and objective parameters (such as quality, convenience, price, capacity and efficiency, etc.) aimed at protecting the commercial and industrial interests of the Group and, in any case, at creating greater value at the same;
- are selected according to criteria of reliability and integrity also according to the need to respect the reference values, the rules of conduct contained in the Code of Ethics and internal procedures, using the written form and in compliance with the hierarchical structure of the Group;
- the Group's policies are communicated to them and specific contractual clauses relating to compliance with this Code of Ethics are envisaged.
The functions in charge must also ensure that continuous awareness and involvement of Suppliers is guaranteed in a pro-active role and a responsible attitude in particular with regard to transparency, communication, compliance with laws and regulations and which fosters awareness. the social and ethical risks and opportunities deriving from their activities.

Relations with customers
In relations with customers, public or private, the Directors, Employees and Collaborators of the companies of the Group are required to:

- develop and maintain favorable and lasting relationships with them, based on maximum efficiency, collaboration and courtesy;
- operate within the framework of current legislation and request its timely compliance;
- ensure that the declarations and certifications made to them are accurate and truthful;
- comply with the commitments and obligations undertaken towards them;
- provide accurate, complete, truthful and timely information in order to allow the Customer to make informed decisions.

In business relationships with Suppliers and Customers, company policies must be respected, making relationships with the utmost fairness, especially in the management and conclusion of contracts, avoiding conflicts of interest, even potential ones.

Without prejudice to the provisions of the paragraph "Relations with the Public Administration", in business relations with Suppliers and Customers, donations, gifts, acts of courtesy or hospitality are prohibited (both directly and indirectly) unless they are of such a nature as not to compromise the image of the Group and cannot be interpreted as aimed at obtaining preferential treatment that is not determined by lawful market rules. In any case, any gifts, acts of courtesy and hospitality that are not part of normal practice, must be adequately documented and communicated to your manager so that they can evaluate their appropriateness. The Employee or Collaborator who receives gifts or preferential treatment from Suppliers or Customers that go beyond ordinary courtesy relations, must immediately notify his / her superior; after the appropriate checks with the relevant management, the companies will, through the appropriate functions, inform the author of the gift, gift etc. on the Group's policy on this matter.

The companies of the Group are committed to guaranteeing maximum competitiveness on the market and, therefore, their commercial policy must be based on compliance with the regulations governing competition, both on the national and international markets.

All recipients of this Code of Ethics must always keep up to date on the legislation in force and consult their hierarchical superior before concluding any agreement or understanding that may have the effects of alleged unlawful competition.

Top management, Employees and Collaborators who act in the name and on behalf of the companies of the Group are required to operate in order to avoid situations in conflict with the interests of the Group itself. By way of example but not limited to, the following constitute a conflict of interest:

- the exploitation of one's functional position for the realization of conflicting interests with company colleagues;
- the use of information acquired in carrying out work activities for one's own benefit or that of third parties and in any case in contrast with the interests of the Group;
- the participation - overt or hidden - of the Employee in the activities of Suppliers, Customers, competitors;
- carrying out work activities of any kind for customers, suppliers, competitors and / or third parties, in contrast with the interests of the Group. In particular, for Employees, the acceptance of any professional assignment offered by third parties must be evaluated in advance with the hierarchical superior and with the Human Resources Director of Milor S.p.A. in order to assess the non-existence of any incompatibilities or situations of prejudice.

Everyone has the duty to promptly report to the competent management any situation that may be considered, even potentially, prejudicial to the rights and interests of the Group so that the same management can proceed, just as promptly, with the necessary protective actions.

Relations with bodies responsible for legally assigned control or auditing activities, and relations with auditing companies, must be based on the utmost fairness, transparency and collaboration, in full compliance with the laws and regulations in force.

In particular, both internal and external auditors must have free access to data, documents and information necessary for the performance of their activities. It is expressly forbidden to prevent or hinder the performance of the control or auditing activity legally attributed to the shareholders, to other corporate bodies or to the auditing company.

The same obligations extend to relations with the Supervisory Body which, within the scope of the responsibilities envisaged by the respective Organization and Management Models voluntarily prepared by the companies of the Group pursuant to Legislative Decree No. 231 of 8 June 2001 "Discipline the administrative liability of legal persons, companies and associations even without legal liability, pursuant to art. 11 of law no. 300 of 29 September 2000 ", has the task of supervising compliance with the existing preventive and control systems, as well as their effective adequacy, in particular in those areas in which any related risks-offenses are identified the activities carried out (Ref. Code of Ethics and Organizational Models pursuant to Legislative Decree 231/2001).

As part of the internal control systems of the Group companies, this Code of Ethics is an integral part of the Organization and Management Models pursuant to Legislative Decree No. 231/2001 adopted voluntarily by the same. In compliance with their full autonomy and their respective commercial and / or production specificities, the companies of the Group that adopt Organization and Management Models in compliance with the principles expressed by Legislative Decree 231/2001 and subsequent amendments and / or additions, are required to carry out risk assessment activities in order to identify the areas in which crimes may be committed and to establish prevention and control systems based on the provisions of the same decree.

The companies of the Group appoint their own Supervisory Body (SB) with autonomous powers of initiative and control with the task of:

- supervise the functioning and observance of the Code of Ethics and company procedures, in particular in those areas in which the risks-offenses pursuant to Legislative Decree 231/2001 possibly connected to the activities carried out are identified - for this purpose, he is free to access to all sources of company information, to view documents and consult data;
- accept and / or report any violations of the Code of Ethics;
- propose any updates to the Code of Ethics and internal protocols in order to adapt them to the law;
- verify, monitor and evaluate cases of violation of the rules established by the Code of Ethics and report it to the relevant departments in order to apply suitable sanctions in compliance with the laws, regulations and CCNL.

The companies of the Group are required to establish adequate communication channels through which all those who become aware of any behavior, within the companies of the Group, contrary to the principles and rules of conduct expressed in this Code can freely report directly and confidentially to his superior and to the Supervisory Body if appointed.

The information acquired by the Supervisory Body and the relevant functions, for the purposes of the necessary investigations, must be treated in such a way as to ensure:
- the confidentiality and anonymity of the reporting party,
- the protection of the whistleblower in the face of any form of retaliation, penalization, discrimination, without prejudice to legal obligations and the protection of the rights of the companies of the Group or of persons accused erroneously and / or in bad faith.

Compliance with the principles and rules of the Code of Ethics must be considered an essential part of the contractual obligations of the Employees. Violations of the rules of the Code of Ethics may constitute non-fulfillment of the main obligations of the employment relationship or a disciplinary offense, with all legal consequences, including with regard to the preservation of the employment relationship, and may result in compensation for damages deriving from the same.

Compliance with the Code of Ethics must be considered an essential part of the contractual obligations assumed by non-subordinate Collaborators and / or subjects having business relationships with the Group. Violation of the rules of the Code of Ethics may constitute a breach of contractual obligations, with all legal consequences, including in relation to the termination of the contract and / or the assignment and may result in compensation for damages deriving from the same. For the violations of the members of the Board of Directors and of the Statutory Auditors, the provisions of the law are valid with the consequent remedies and sanctions.

The companies of the Group undertake to foresee and to impose, with coherence, impartiality and uniformity, sanctions proportionate to the respective violations of the Code and in compliance with the current provisions on the regulation of employment relationships.