Code of Ethics

Purpose

This Code of Ethics defines the values, conduct principles and behavioral standards that guide Futura AI Srl SB in all its activities, internal relations and external interactions.

The document aims to support lawful, responsible and transparent conduct, consistent with the company's business purpose, technological role and benefit-oriented identity.

Scope

This Code applies to directors, executives, employees, collaborators, consultants, suppliers, partners and any third party acting on behalf of or in the interest of Futura AI Srl SB.

All recipients are required, within the limits of their responsibilities and roles, to know and respect the principles set out in this document.

Core values

Futura AI Srl SB recognizes the following as its foundational values:

• legality in every business and professional activity;
• integrity, fairness and good faith in decision-making and conduct;
• transparency in communications, commitments and relationships;
• respect for people, dignity, diversity and equal opportunity;
• responsibility in the design and use of technology;
• protection of information, confidentiality and security;
• accountability toward clients, partners, institutions and the broader community.

Compliance with law

The company operates in compliance with applicable laws, regulations, contractual obligations and internal rules. No objective, commercial interest or performance target may justify conduct contrary to the law or to this Code.

Recipients of this Code are expected to avoid any behavior that may expose the company to legal, reputational, operational or ethical risk.

Relations with clients

Relations with clients must be based on professionalism, clarity, reliability and mutual respect. The company is committed to presenting its services honestly, defining deliverables clearly and acting consistently with agreed expectations.

Any misleading statement, omission of material information or unfair commercial conduct is contrary to this Code.

Relations with suppliers and partners

Suppliers and partners are selected according to objective criteria including competence, reliability, integrity, quality and consistency with the company's standards and values.

The company rejects favoritism, improper advantages and any form of conduct that may compromise impartiality or sound business judgment.

Human resources and workplace conduct

Futura AI Srl SB promotes a work environment based on dignity, respect, merit, collaboration and professional growth.

Harassment, discrimination, intimidation, abuse of authority or any conduct that undermines personal dignity or creates a hostile environment is not tolerated.

The company values diversity of backgrounds, skills and perspectives as a factor of innovation and organizational strength.

Confidentiality and information protection

Information acquired in the course of work must be handled with care, only for legitimate purposes and according to applicable confidentiality, security and data protection requirements.

Recipients must protect company information, client data, intellectual assets and any non-public information from unauthorized access, disclosure, alteration or misuse.

Responsible technology and AI

As a company operating in artificial intelligence and advanced digital systems, Futura AI Srl SB recognizes a specific duty to develop and apply technology responsibly.

In particular, the company is committed to:

• considering the intended use and foreseeable risks of technological solutions;
• promoting proportionality, traceability and human oversight where appropriate;
• avoiding deceptive, reckless or unjustifiably opaque uses of AI;
• taking into account data quality, reliability and security in system design;
• supporting ethical reflection in product and project decisions.

Conflicts of interest

Recipients of this Code must avoid situations in which personal interests may interfere, or appear to interfere, with the interests of the company.

Any actual, potential or perceived conflict of interest shall be disclosed promptly according to internal reporting lines and handled with transparency.

Gifts and benefits

Offering or accepting gifts, hospitality or other benefits is permitted only when it is lawful, modest, occasional, transparent and not capable of influencing independent judgment.

Any gift or advantage that may be perceived as improper or intended to obtain preferential treatment is prohibited.

Accounting integrity and records

The company is committed to maintaining truthful, complete and accurate records of transactions, decisions and relevant business activities.

Any falsification, concealment or alteration of information, documentation or supporting records is strictly prohibited.

Health, safety and well-being

The company is committed to promoting working conditions consistent with health, safety and organizational well-being, in accordance with applicable obligations and proportional to the characteristics of its activities.

Each recipient is expected to contribute responsibly to a safe, respectful and sustainable working environment.

Reporting concerns

Anyone subject to this Code is encouraged to report, in good faith, conduct that may be inconsistent with the law, with internal rules or with the principles set out herein.

Reports shall be managed with seriousness, confidentiality and protection against retaliation, in accordance with applicable rules and internal procedures.

Implementation and review

This Code is communicated to relevant stakeholders and periodically reviewed to ensure its continued adequacy with respect to the company's evolution, regulatory context and operational risks.

The company promotes awareness of this Code through internal communication, onboarding and, where appropriate, training and governance measures.

Approval

This Code of Ethics is approved by the management of Futura AI Srl SB and constitutes a reference standard for conduct across the organization.