GOVERNANCE INFORMATION

ETHICAL BEHAVIOR AND MORAL STANDARDS

We are strongly committed to running our activities in accordance with local regulatory frameworks and with the highest ethical and moral standards, thus actively working to prevent any type of unethical business practice.

Zero tolerance for corruption

We have a policy of zero tolerance towards corruption and, in 2017, the group Anti-Corruption Policy was approved, intending to ensure daily activities are carried out ethically, protecting value creation and those core values on which the Company's activities are founded. The provisions and guidelines contained in the Policy are inspired by our corporate culture and by the behavioural principles stated in our Code of Ethics, which have been developed by analysing the activities potentially exposing Amplifon to corruption risk.

To support this, during 2020 a new Whistleblowing System was introduced with the aim to guarantee a safe, respectful and protected workplace. It constitutes a set of rules and means of communication to report, with the guarantee of confidentiality, any breach or well-founded suspicion of a breach, as well as any behavior that does not comply with the Code of Ethics, the Anti-Corruption Policy, internal policies and procedures (such as, for example, the Organizational Model 23 for the Parent Company), as well as laws and regulations applicable to each company of the Group.

Business ethics and fair competition

All our people and those representing us in various ways are required to uphold the high standards established in our Code of Ethics.

We have an internal control and risk management system, a set of rules, procedures and organizational structures to identify, measure, manage and constantly monitor the main risks.

Lastly, as stipulated in our Code of Ethics, people in direct contact with customers must provide full and accurate information about products and services, as well as any other information necessary to be able to make an informed decision.

In addition, we respond to competition by constantly monitoring market developments and guiding its investments primarily towards differentiating the service we offer and making new acquisitions, always maintaining a fair competition approach.

TAX-RELATED TRANSPARENCY

The Group’s Tax Strategy, approved by Amplifon S.p.A.’s Board of Directors during the meeting held on March 3rd, 2022, defines the suitable methods for managing the tax variable within the internal control system. Shaped by principles of honesty, integrity, and transparency in the relationship with the tax authorities, this Strategy aims to ensure tax legislation is correctly applied and that long-term value is created for all the stakeholders.

SUPPLIERS QUALIFICATION AND STANDARDS OF BEHAVIOR

Responsible management of procurement and the supply chain is essential to guarantee compliance with the highest ethical standards along the value chain. Amplifon rejects suppliers which admit, in violation of the principles of the freedom and dignity of people and fundamental human rights, to the exploitation of forced and child labor, as well as any form of personal discrimination. During the qualification phase, all suppliers acknowledge and sign Amplifon’s Code of Ethics and, starting from 2019, all suppliers of hearing aids whose contract is subject to renegotiation are required to recognize and comply with the principles set forth in Amplifon’s Sustainability Policy. In addition, at the start of 2022, a new Supplier Code of Conduct was defined and adopted, which describes the principles and standards of conduct required of all of Amplifon’s suppliers and business partners. From 2023, the mandatory acceptance of this Code was included in the qualification process for new suppliers, so that any new supplier signs up to it and its proactive implementation. The progressive adoption of the Supplier Code of Conduct and the identification of potential ESG risks of suppliers are made possible by the new global supplier assessment framework, implemented in 2023. It consists of two internal tools: the first to assess a supplier's level of inherent ESG risk based on product category, and the second to assess residual ESG risk based on ESG information and data requested from the suppliers themselves via a questionnaire filled out by them.

OUR SUPPLIER CODE OF CONDUCT

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CYBERSECURITY AND DATA PRIVACY

Privacy and data protection are increasingly in the spotlight. Protecting the data we hold is more than a priority for us: it is an essential condition to earn the trust people place in us every day. Collecting and processing information is not only vital for us to provide our services, but it also enables us to innovate and guarantee the most advanced solutions.

THE HIGHEST PRIVACY STANDARDS

We continually invest in data protection through a set of management tools for the application of the requirements as foreseen by national and international legislation. Upon the entry into force of EU Regulation 2016/679 (GDPR), we have implemented all the necessary steps to be fully compliant with legislation throughout Europe.

During 2024, in order to improve Amplifon's privacy posture and cybersecurity, numerous activities were implemented including: training courses on cybersecurity issues, internal communication campaigns to increase awareness on the subject, guidelines for the management of cross-border transfers of personal data and on the use of artificial intelligence, and the performance of impact assessments on more sensitive processing. The main objective of the Global Privacy Policy is to ensure the fair, secure and lawful processing of personal data of employees, customers, prospects and others. The monitoring process includes regular audits, risk assessments and continuous updates to ensure that the protection measures remain effective.

PRIVACY & SECURITY BY DESIGN

When designing the digital services offered by Amplifon, such as the multichannel ecosystem, the Amplifon App and Ampli Care, the first requisite taken into consideration is always data privacy and security (privacy and security by design). With reference to the Amplifon App, consent for data processing for marketing and profiling purposes was updated in conformity with regulations and users can revoke their consent at any time.

GOVERNANCE AND SECURE BEHAVIORS

In 2021 we created a dedicated cybersecurity team, furtherly reinforced, to ensure increasing coverage of cyber issues, to create shared responsibilities and strengthen active collaboration across functions.

Specific training is provided to all employees to enhance their awareness of risks and cyber threats as well as foster secure behavior throughout the organization, in a continuous learning process. Particularly, our hearing care professionals and in-store staff are trained to correctly handle customers’ sensitive data. Furthermore, our Code of Ethics prohibits any data disclosure and utilization for purposes other than those established

IT SECURITY

Initiatives were continuously implemented to reduce cybersecurity risks, with a particular focus on the security of networks, services and endpoint equipment, improvement of monitoring, detection activities as well as increasing the awareness of all collaborators. Investments in the ICT architecture and security protection/detection/response against new IT security threats continued, thereby contributing to Amplifon’s digital transformation.

Moreover, the activities to obtain the ISO27001 (Corporate) certification and HiTrust continued, in the light of the SOC2 certification already valid in the United States. Moreover, we continued the process to formalize the Information Security Document Framework, aimed at regulating the security processes involving people and technologies.

In addition to these activities, Amplifon focused on the adaptation to the requirements of the new European Network and Information Systems Directive 2 (NIS2).

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