Organisation, Management and Control Model 231

The birth of Blupura – The inspiring principles of the Model

Blupura S.r.l. (henceforth, “Blupura” or sometimes “Company”) was established in January 2008 on the intention of the two founding
partners, Luca Costantini and Gianni Grottini, and operates in the sectors of design, production, assembly, import and export, distribution,
marketing, rental, maintenance of coolers and of dispensers of drinking water (and of other non-alcoholic and alcoholic drinks) for domestic
and professional use, fountains for public and private use, water features, ice makers and ice dispensers for domestic or professional use and
systems and equipment for the filtration, purification and treatment of water for domestic or professional use.
In May 2017, Blupura became part of the Culligan Group, expanding its presence on the Italian and international market. Blupura operates in
Europe and in the USA with its own subsidiary, Blupura USA.
The Company has its registered office in Cadriano dell’Emilia (Bologna) and its administrative and production headquarters in Recanati (Macerata),
where its employees work in various numbers who perform tasks of a productive, administrative-financial as well as of a commercial and
technical assistance nature.
Blupura S.r.l., as part of the existing preventive control system and in compliance with the policies adopted by the Culligan Group, has decided
to adopt an Organisation, Management and Control Model (sometimes, “Model 231” or “Model”) in order to develop and implement a system
of governance adhering to ever higher ethical standards, capable of promoting the constant diffusion of the culture of control and greater
awareness of responsible and aware behaviour, as such suitable for the avoiding and/or reduction of the risk of crimes envisaged by Italian Legislative
Decree 8 June 2001 no. 231 on the “Discipline of the administrative liability of legal persons, companies and associations even without
legal personality, pursuant to art. 11 of the law of 29 September 2000, no. 300 “ (henceforth “Italian Legislative Decree 231/2001” or
“Decree”).In line with the new regulatory scenario and international and national self-regulation, the Company has also undertaken a series of
initiatives aimed at concretely implementing the Model of compliance adopted. This entailed for the Company the need to conform its structure
and its management methods to the afore-mentioned Model through the following interventions:

• Risk mapping, analysis and assessment;

• Appointment of the Supervisory and Control Body;

• Verification of the adequacy of the procedures adopted for the purpose of creating an adequate preventive control system;

• Verification of the existence of a sufficiently formalised and clear organisational system regarding the so-called “reporting lines” (organisational
charts);

• Verification of the adequacy of the Information Systems;

• Review of signature powers and of authorisation levels;

• Adoption of management control systems;

• Preparation of an internal and external communication plan;

• Staff training and sanction system;

• Forecast of periodic audits.

In compliance with the indications provided by the jurisprudence formed on Italian Legislative Decree 231/2001, according to which the Organisation,
Management and Control Model must develop from an organisational – and not only legal – formal vision of corporate phenomena,
Blupura has developed and implemented a Model capable of fulfilling its function efficiently and effectively.
The aim of the Company to adhere to the principles underlying Italian Legislative Decree 231/2001, of which this Model constitutes evidence, is
also reflected in the Group Code of Ethics, which contains the fundamental principles and values which inspire the Culligan Group (and, therefore,
the Company), which Blupura has implemented and which constitutes an integral and substantial part of this Model. Through these, the company
expresses the commitments and ethical responsibilities in the conduct of business and corporate activities assumed by the Company, by its
subsidiaries as well as by collaborators, whether they are directors or employees of such companies, as well as by all those who work for/with the
Company and for/with the companies of the Culligan Group, whatever the relationship – even temporary – that binds them to these.

Objectives and recipients of the Model

The Model has the purpose of preventing the risk of committing the offences envisaged by Italian Legislative Decree 231/2001 and is
addressed – in addition to the Supervisory Body – to all those persons who work in any capacity for the Company, whatever the relationship –
even temporary – that binds them to it, and/or to whoever maintains relations with the Company, in particular:

• Directors;

• Members of the other corporate bodies, as well as any other person in a senior position, meaning any person who holds

• Representation, administration or management functions in the Company;

• Employees (including managers), also temporary or part-time workers and agency workers who have been assigned powers; collaborators,
interns, meaning those persons who maintain relationships of representation, commercial distribution or coordinated and continuous
collaboration relationships with the Company, mainly personal and without the constraint of subordination;

• Occasional and ongoing consultants;

• Intermediaries, commercial partners, dealers, professionals and suppliers of goods and services;

• Any other counterparty who maintains contractually regulated relationships with the Company.

Download the Model 231