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Legislative Decree of June 8 2001 n. 231 introduced into the Italian legal system the administrative responsibility of Entities — including corporations — for certain crimes committed by directors, managers or employees in the interest or for the benefit of the Entity itself.

The “231 Organizational Model” is a document that falls within the forms of control envisaged by Legislative Decree 231/2001 and, if properly implemented, exempts the legal entity from liability and also provides a guide for all employees and collaborators, setting out clear guidelines to prevent crimes and corruption practices.

Each of the companies belonging to Ecolab Group in Italy adopted its own “231 Organizational Model”, with the aim of building a structured system of guiding principles and operating procedures, based on sound corporate management criteria.

The task of supervising the functioning, updating and concrete application of the “231 Organizational Model” is entrusted to a Supervisory Board for 231, a body, specific for each company, composed by two independent external members and one internal member.

To contact each Supervisory Board and report any violations of the “231 Organizational Model” and of the code of conduct:

• Ecolab Srl: odv.ecolabsrl@ecolab.com
  
• Ecolab Holding Italy Srl: odv.ecolabholdingitaly@ecolab.com
  
• Ecolab Production Italy Srl - Stabilimento di produzione di Rozzano: odv.ecolabproductionrozzano@ecolab.com
  
• Nalco Italiana Srl: odv.nalcoitaliana@ecolab.com
  
• Nalco Italiana Manufacturing Srl: odv.nalcoitalianamanufacturing@ecolab.com

For any reports of wrongdoing, including those related to the violation of the 231 Organizational Model and the Code of Conduct, please refer to the procedure found at the following link: EU Whistleblower Reporting and Investigation Procedures (ecolab.com).

The “Organizational Models 231” are part of a broader governance policy of the Ecolab Group, which is based on ethics and integrity.

Ecolab employees worldwide are required to complete training on the Code of Conduct and to declare, on an annual basis, their adherence to the principles contained therein.