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“BetaGlue Therapeutics Joint-Stock Company” (hereinafter “BetaGlue Therapeutics SpA” or the “Company” or “BetaGlue”) is a highly innovative company engaged in the development of a project based on the treatment of solid tumors and surgical resection margins with a proprietary beta-emitting bio-compatible matrix, delivered to the target through dedicated devices, called BAT-90; the matrix is made up of two components, both classified as medical devices, resulting in itself as a medical device from a regulatory point of view and therefore benefiting from a simpler approval path. BetaGlue’s technology is the first to allow highly controlled delivery of radionuclides directly into the tumor mass (or on the surgical bed after its resection), effectively bringing precision therapy into radiation therapy. In this way, therapeutic radiation is concentrated where it is needed, increasing efficacy and at the same time reducing the risk of undesirable side effects, both locally and in the rest of the patient’s body. The amount of energy needed is administered by a simple intraoperative method, for maximum efficacy and safety of patients and medical/healthcare staff. This controlled administration of radionuclides falls within the field of loco-regional therapies for the treatment of tumors and compared to external beam radiotherapy (EBRT), has several potential advantages: high dose of radiation where it is needed (better efficacy), low penetration into surrounding tissues, low impact on blood vessels, high control of the energy administered (limited side effects). BetaGlue has designed a device to ensure precise delivery of the required energy dose where it is needed, thereby overcoming the disadvantages of external beam radiotherapy (EBRT). The possible applications of this beta-emitting radiotherapy range from intra-tumor treatment of unresectable or metastatic tumors, to the treatment of surgical margins after tumor removal to avoid local recurrence.


This Code of Ethics (the “Code of Ethics” or the “Code”) is an integral part of the organizational, management and control model adopted by BetaGlue Therapeutics SpA (the “Model”) and subsequent amendments, pursuant to Legislative Decree no. 231 of June 8, 2001, and was approved by the Board of Directors with resolution of July 31, 2023.

The Code of Ethics is the main means of spreading ethical culture within the Company. It represents the main values that inspire the company’s actions and expresses the guidelines of conduct to which the conduct of all operators must comply, both in internal relations and in relations with external stakeholders.


Given that the impact and relevance of a Code of Ethics must be proportionate with the ability of an organization to foster the emergence of a climate of sharing of the principles enunciated, the Code of Ethics aims to define, and share, a set of rules of conduct that must be observed by all those who operate in the name and on behalf of BetaGlue Therapeutics SpA.

It therefore has relevance both in internal professional relations and in the professional and commercial relations that BetaGlue Therapeutics SpA establishes outside its organization. Those who hold positions of responsibility within the Company are required to set an example for staff in compliance with the Code of Ethics and the rules contained therein.

Compliance with the Code of Ethics is required to:

  • the Board of Directors and those who carry out management activities of BetaGlue Therapeutics SpA, who are responsible for conforming all actions to compliance with the values and principles of conduct set out, spreading knowledge of them, and encouraging their sharing by employees and collaborators;
  • employees, who are required to act in compliance with the Code of Ethics and to report any infringements;
  • external collaborators, suppliers and, more generally, all customers, who must be duly made aware of the rules of conduct contained in the Code, so as to inform you of their conduct for the entire duration of the relation with BetaGlue Therapeutics SpA.

BetaGlue Therapeutics SpA undertakes to promote and guarantee adequate knowledge of the Code of Ethics and to ensure compliance with the principles and rules contained therein. All those who, in any capacity, relate to BetaGlue Therapeutics SpA are required to be aware of this Code and to contribute to its implementation, and to this end the Company’s management promotes and ensures its knowledge.

The Code of Ethics is brought to the attention of its addressees through appropriate communication activities. In particular, in order to ensure the correct understanding by all the staff of BetaGlue Therapeutics SpA, in agreement with the SB, specific training activities are prepared to promote knowledge of the principles and rules contained therein, and we undertake to deepen and update the Code of Ethics in order to adapt its content to the evolution of civil sensitivity, as well as the regulations having greater relevance for the aspects covered by this Code.

BetaGlue Therapeutics S.p.A. undertakes to promote, in its internal communication activities (adequate information in the letter of employment for new personnel) the widest information on issues related to the prevention of crimes that may result in administrative liability pursuant to Legislative Decree no. 231/2001.

PART TWO: Ethical Principles

The principles indicated below constitute the ethical model of reference considered fundamental by BetaGlue Therapeutics SpA to which the Board of Directors and all other stakeholders must be inspired in order to promote the proper functioning, reliability, and image of the Company.


BetaGlue Therapeutics SpA conducts its activities in full compliance with the constitutional principles, laws, regulations, customs, and commercial practices, as well as the codes of ethics, the provisions of this Code, the Model and internal procedures, and, in general, all the regulations applicable to it, both national and international.

The recipients of the Code of Ethics not only have the obligation to know, but also to comply with the legal provisions that apply to the activities they conduct, bearing in mind that in no case is the pursuit of an interest of BetaGlue Therapeutics SpA in violation of the law and others listed above tolerated.


The Personnel of BetaGlue Therapeutics SpA must adopt a correct and honest attitude, both in the performance of their duties and in relations with other members of the Company, avoiding pursuing illicit or illegitimate purposes, or creating situations of conflict of interest, with a view to an undue advantage, their own or that of third parties. Under no circumstances can the interest or advantage of the Company justify fraudulent conduct.


The Board of Directors and those who are called upon to perform management functions, as well as all employees and those who interact with BetaGlue Therapeutics SpA, avoid, and disclose any situation, even potential, of conflict of interest, which arises when they pursue purposes other than those of BetaGlue Therapeutics SpA and/or personally take advantage of opportunities related to said company.

Situations of conflict of interest may be defined as those by virtue of which the person can acquire a personal advantage from decisions in which he participates, even in cases where such membership does not generate the incompatibilities provided for by law or other rules.

In particular, the following are to be considered in conflict:

  • the exploitation of their own position for the realization of its own interests or those of third parties that conflict with those of BetaGlue Therapeutics SpA;
  • the use of information acquired in the performance of work activities for the benefit of their own or third parties;
  • the ownership of financial shareholdings, joint interests or interests with suppliers, customers or competitors;
  • the acceptance of positions or assignments of any kind with suppliers, customers and competitors, if not formally approved by BetaGlue Therapeutics SpA.

The recipients of this Code undertake to implement all possible actions for the prevention of corruption, which are not the mere bureaucratic application of the provisions of the legislation but aimed at improving the organization itself.

They do not ask for, nor accept, for themselves or for others, gifts or other benefits, as required by the regulations in force, with the exception of gifts of modest value, occasionally made as part of normal courtesy relations. By modest value we mean those goods with a value not exceeding, as a guideline, 150 euros, also in the form of a discount, which can, therefore, be received without exceeding, cumulatively, the limit established in relation to the single calendar year. If, in the calendar year in question, the gifts and other benefits exceed the limit indicated, the employee must immediately make them available to the Company for return. In any case, regardless of the possibility that the act constitutes a crime, the employee does not ask for, or solicit, for himself or for others, gifts or other benefits for performing or having performed acts of his office.

The Company’s management promotes all forms of development of internal control and external control activities in order to make these activities more effective and efficient. They encourage the full application of the institution of reporting misconduct by employees as a form of combating corruption in order to encourage any form of unlawful conduct within the Company.

Each Director, Statutory Auditor, employee, collaborator and consultant is required to immediately report any situations of conflict of interest, including potential ones, to the Supervisory Body and to comply with the internal procedures defined by BetaGlue Therapeutics SpA to regulate such contingencies.


BetaGlue Therapeutics SpA communicates in a simple and understandable way, to prevent specialized and bureaucratic language from preventing those who enter into a relation with the Company from fully exercising their rights. It behaves with courtesy and willingness to listen, because the spirit of welcome is necessary to understand the questions and needs of those who turn to it.

The Company pays equal attention to the questions of each interlocutor, according to the principle of equal treatment, avoiding any discrimination, and responding in the most appropriate manner as accurate and exhaustive as possible to each request for information. It also promotes tools for listening, measuring the degree of satisfaction of the users of its services, communication and dialogue.


In carrying out its activities, BetaGlue Therapeutics SpA undertakes, both internally and externally, to comply with the following guidelines:

  • accurate, clear, truthful and correct information, communications and instructions – from an economic, financial, legal, ethical and social point of view;
  • ensure the traceability of every single company operation, through the adoption of procedures that guarantee the correct recording, detection and storage of the related documentation;
  • inspire the company’s activities to a precise criterion to “attribute” the processes carried out by specific company functions and/or by specific subjects;
  • check that all contracts with parties, both internal and external, include clauses that are always understandable, clear and correct.

BetaGlue Therapeutics SpA ensures compliance with the rules relating to the protection of privacy and personal data, taking particular care of every aspect that concerns the dignity of the person. In particular, except in the cases provided for by law, the addressees of the Code are required to avoid providing information regarding ongoing investigation, inspection, or investigation activities, and not to disclose the contents of the provisions relating to ongoing proceedings before they have been officially approved by the competent bodies.

BetaGlue Therapeutics SpA, by complying with the provisions and adopting the security measures required by the European Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data, as well as on the free movement of such data and other relevant regulatory provisions, guarantees the confidentiality of the information in its possession and refrains from collecting data in violation of the law. The Company aims to inform each employee about the nature of the personal data processed by the Company, the methods of processing, the areas of communication and any data relating to him/her.

In any case, it is forbidden to carry out any investigation into the ideas, preferences, personal tastes, and in general, relating to the private life of employees.


In order to qualify the service, BetaGlue Therapeutics SpA pursues the systematic development of research as part of its mission to provide services, meeting up-to-date high-quality standards, to patients and subjects with whom it has professional relations.

It also ensures ethical, scientific, and methodological correctness of research, in full respect of the patient. To this end, it asks its employees and collaborators, in any capacity, to carry out their activities with the utmost diligence, professionalism, accuracy and humanity. With a view to continuous improvement, the Company considers users’ comments and suggestions.


BetaGlue Therapeutics SpA guarantees the physical and moral integrity of its employees, collaborators and, in general, of stakeholders: it ensures safe and healthy conditions in all workplaces; requests or threats aimed at inducing people to act contra legem, in violation of the Code of Ethics or to adopt behaviours contrary to the convictions and moral values of each person are not tolerated.


BetaGlue Therapeutics SpA is sensitive to the prevention of accidents and the protection of the safety and health of workers in the workplace. The activities are carried out in such a way as to allow adequate prevention and a healthy and safe working environment, in compliance with the rules on safety and health (Legislative Decree no. 81/2008). The safety and healthiness of the working environment are guaranteed through the monitoring, management and prevention of risks associated with the performance of professional activities.

BetaGlue Therapeutics SpA ensures the protection and respect of the environment, also in the name of future generations, and bases its activity on compliance with national regulations on environmental protection. To this end, in carrying out its activities, the Company undertakes not to pollute but to constantly optimize the use of resources and to ensure the correct disposal of the waste produced. At the same time, it takes measures to preserve the environment by raising awareness of the possible environmental consequences and impacts of their activities so that they work to reduce causes and effects.

PART THREE: External Relations


In its relations with customers, BetaGlue Therapeutics SpA adopts behaviours inspired by the principles of transparency, reliability, responsibility, quality, and free competition.

In particular, the Company undertakes:

  • to carefully comply with the provisions of this Code and the internal procedures relating to the management of relations with customers, as well as all the contractual provisions defined by current legislation;
  • not to engage in arbitrary, discriminatory, predatory, or unfair behaviour;
  • to avoid any initiative that may cause unjustified favouritism, giving customers an advantage over others;
  • not to receive money or benefits, even if of modest value, for the execution, certification, or adoption of acts contrary to official duties, or aimed at obtaining illicit benefits;
  • not to accept or receive payments, direct or indirect, as well as offers or promises of payment or donations of valuable goods for the exercise of their duties and/or to carry out official activities;
  • not to accept or receive payments, direct or indirect, as well as offers or promises of payment or donations of valuable goods from those who request an undue advantage, of an economic or non-economic nature, for themselves or for third parties, which can be achieved through the influence of public entities to inform the customer exhaustively at all stages of the pre-contractual and contractual relation;
  • not to resort to unfair practices or terms;
  • to fulfil contractual obligations in a timely and correct manner;
  • to respond to customer suggestions and/or complaints.


The principles of the Code of Ethics are applied in commercial relations with the Company’s suppliers.

All contracts with suppliers are based on extremely clear and transparent relations.

Relations with suppliers are governed by the provisions of this Code, by specific internal procedures and are subject to constant and careful monitoring.

The selection of suppliers is made by the dedicated personnel, on the basis of objective and documentable criteria, aimed at seeking the highest quality of service and achieving the most competitive economic conditions.

In managing relations with its suppliers, the Entity is required to:

  • Carry out an impartial and independent selection process based solely on objective criteria, such as price, quality, payment conditions, delivery times, support services and compliance with all legal provisions envisaged;
  • ensure that scientific and research advisers are selected solely on the basis of quality and professional expertise;
  • avoid conflicts of interest with suppliers; if they occur, they must be immediately reported to the SB and processed as required by internal procedures;
  • create, in the exclusive interest of the Company, through the proper management of the commercial negotiations with suppliers, profitable long-term relations;
  • ensure that any acts of commercial courtesy are never such as to give rise to suspicions of wrongdoing and compromise the company’s image;
  • ensure that any attempt or case of unjustified alteration of normal commercial relations (e.g. offers of money or other benefits by a supplier in exchange for obtaining confidential information or initiating actions or behaviours that may favour said supplier in the purchasing process) is immediately reported to the direct hierarchical superior and to the SB;
  • acquire all information relating to the supplier by lawful means and process such data in compliance with the laws in force;
  • ensure that contracts with suppliers always include a clause accepting the principles of this Code;
  • not to accept or receive payments, direct or indirect, as well as offers or promises of payment or donations of valuable goods for the exercise of their duties and/or to carry out official activities;
  • not to accept or receive payments, direct or indirect, as well as offers or promises of payment or donations of valuable goods from those who request an undue advantage, of an economic or non-economic nature, for themselves or for third parties, achievable through influence over public entities.

The violation of the provisions of this Code by the suppliers constitutes a serious breach of contract such as to determine the unilateral and immediate termination of the contract and the compensation of any damages deriving from such violation against BetaGlue Therapeutics SpA.


Collaborators in any capacity and consultants are required to behave with correctness, good faith, and loyalty, complying with this Code of Ethics, the company regulations and the instructions and prescriptions received, each for their own area of competence.

The procedures and operating instructions prepared internally are intended to avoid risks of activation of improper and/or illicit assignments.

The identification and selection of collaborators and consultants follow rules of impartiality, autonomy and independence of judgment. In awarding professional assignments, BetaGlue Therapeutics SpA takes into account the requirements of: professional competence, reputation, independence, organizational capacity, fairness and timely execution of the contractual obligations of the assignments entrusted.

In managing relations with self-employed collaborators/consultants, the Company undertakes to:

  • not to accept or receive payments, direct or indirect, as well as offers or promises of payment or donations of valuable goods for the exercise of their duties and/or to carry out official activities;
  • not to accept or receive payments, direct or indirect, as well as offers or promises of payment or donations of valuable goods by those who request an undue advantage, of an economic or non-economic nature, for themselves or for third parties, which can be obtained through influence over public entities;
  • Prior to taking charge, self-employed collaborators/consultants must declare:
  • not to be in a situation of conflict of interest with other related parties;
  • to have/not have relations with other related parties;
  • to have any subordinate employment relations with public or private bodies;
  • to provide or not to provide activities in any capacity in public or private health or social-health facilities in Italy and abroad or in facilities affiliated or accredited with the Italian NHS.


Relations with the Public Administration are based on the principles of fairness, transparency and efficiency and full compliance with the laws and provisions of this Code and must be implemented in compliance with the specific provisions contained in the Anti-Corruption Guidelines.

It is forbidden to offer and disburse money or other benefits, even as a result of unlawful pressure in a personal capacity, on public officials or persons in charge of public services with the aim of promoting or favouring the interests of BetaGlue Therapeutics SpA or with the aim of inducing them to perform an act contrary to their official duties. This rule of conduct cannot be circumvented by resorting to forms of donation that, in apparently different ways (assignments, consultancy, sponsorship, gifts and/or gifts, etc.), have the same purpose as the above prohibited.

It is also forbidden to behave, including the production of untruthful or omissive documentation, capable of influencing the decisions of the officials who deal with or take decisions on behalf of the Public Administration; or provide or promise to provide, solicit or obtain confidential information and/or documents, or in any case, such as to compromise the integrity or reputation of one or both parties in violation of the principles of transparency and professional fairness.

The behaviours described are forbidden both in the course of the business negotiation and once this has come to an end.

With reference to the disbursement of public funds, each recipient must refrain:

  • the use of statements attesting to untruthful facts and news, or omitting information to obtain, for the benefit and in the interest of the Company or of the Company, contributions, loans or other disbursements granted, for any reason by the P.A.;
  • the use of contributions, loans and other disbursements granted by the P.A. for purposes other than those for which they were assigned.

With reference to negotiations with the PA and participation in calls for tenders for obtaining public funding, contributions and disbursements, each recipient is required to:

  • operate in accordance with the principles of fairness, transparency and good faith;
  • assess the adequacy and feasibility of the services provided for in the call for tenders;
  • maintain transparent and fair relations with PA officials;
  • fulfil contractual obligations diligently and punctually.

In all cases in which one of the recipients receives implicit or explicit requests for benefits of any kind from a public official or a person in charge of a public service, he or she is immediately required to:

  • inform his/her hierarchical superior and the SB;
  • suspend any relation with the public official or the person in charge of a public service from which the request has been received.


BetaGlue Therapeutics SpA does not finance political and trade union organizations, their representatives and candidates and refrains from any improper pressure, direct or indirect, against political and trade union representatives.

No contribution is also made, directly or indirectly, to political parties, movements, committees, associations with interests or organizations attributable to politically exposed subjects.

In consideration of its research and scientific activity, the Institution may provide contributions or sponsor non-profit associations with regular statutes and deeds of incorporation that are of high cultural or charitable value, which involve a considerable number of citizens and that have among their purposes those related to the progress of medicine, scientific research, teaching, environmental and health protection.

Contributions and sponsorships to associations that promote social projects, art and sport are also allowed, but only if the very high quality and reputation of the organizations themselves are proven.


The recruitment of human resources meets the criteria of objectivity, transparency and compliance with private law regulations and the provisions of the collective labour agreement, avoiding any form of favouritism.

The selection procedures shall be based on the criterion of ascertaining individual professional aptitudes and skills in the light of the performance of the tasks to which the staff is assigned, the organisation of the offices and the programmes to be implemented.

The information requested, during the personnel selection phase, is exclusively aimed at verifying the professional and psycho-aptitude requirements of the candidate and is processed in compliance with the provisions for the protection of the confidentiality of personal data.

All the staff is hired by the Company with a regular employment or collaboration contract.

The Company complies with the provisions of the law in force on employment and is opposed to any form of irregular work. The employment/collaboration takes place in compliance with the collective bargaining regulations of the sector and the social security, tax and insurance regulations. The Entity guarantees the dignity of employees and collaborators and condemns all forms of exploitation of the person.

The acceptance of the assignment – whatever its nature as structured, non-structured, scholarship holder and collaborator in any capacity – will be based on an effective understanding of the obligations provided for by the contract- Therefore, upon the establishment of the employment/collaboration, each employee and collaborator receive accurate information relating to:

  • characteristics of the function and tasks to be performed;
  • regulatory and remuneration elements, as regulated by the applicable national collective labour agreement;
  • rules and procedures to be adopted, in order to avoid possible health risks associated with employment;
  • privacy legislation;
  • rules of conduct governed by this Code of Ethics;
  • procedures that constitute the implementation of this Code of Ethics.

The Company protects all employees and collaborators and guarantees optimal conditions for the performance of their duties, especially with regard to the categories to which the law reserves special protection.

PART FOUR: Organization and Management of Internal Resources


The recipients of the Code use the goods that BetaGlue Therapeutics SpA makes available to carry out the work activity:

  • in a manner strictly relevant to its business and committing itself to an appropriate, efficient, correct and rational use;
  • always keeping in mind the collective interest in the optimal use of public resources, energy sources and natural resources, also with a view to protecting the environment and future generations, making its contribution to the disclosure and awareness of sustainable development and managing its activities in an environmentally friendly way.


The Company undertakes to protect its assets, in all its components, in order to avoid loss, theft and damage. The assets that are part of the estate can only be used for reasons related to the activities that BetaGlue Therapeutics SpA carries out, and in no case for personal or illegal activities.


The intellectual property rights deriving from any ideas developed in the course of work or through the use of BetaGlue Therapeutics SpA resources belong to the Company itself, which becomes the exclusive owner of the “individual property rights” and retains the right to use them in the manner and time it deems most appropriate in accordance with current legislation.

In particular, with regard to the prevention and management of conflicts of interest related to intellectual property rights apply to the agreements entered into by the data subject with BetaGlue Therapeutics SpA implementing the principles set out in this Code of Ethics and, in any case, the company’s provisions.


Scientific research activity. Employees and collaborators are required to comply with current legislation and company procedures in the field of scientific research, to monitor design and development processes and to act transparently.

Accounting activity. The Company undertakes to comply with the rules of correct, complete and transparent accounting, in accordance with the criteria indicated by law and by the accounting principles adopted, also asking its employees and collaborators in compliance with company regulations and procedures, to act with transparency in relations with the auditing firms indicated and the Board of Statutory Auditors and to provide maximum cooperation in carrying out their respective verification and control activities.

Employees and collaborators undertake to ensure that each transaction is correctly recorded in the accounts, according to the criteria indicated by law and applicable accounting standards, as well as authorised, verifiable, legitimate, consistent and congruous.

Employees and collaborators undertake to keep adequate and complete supporting documentation of the activity carried out in the records, so as to allow checks to be carried out to ascertain:

  • accurate accounting records;
  • the immediate determination of the characteristics and motivations behind the transaction;
  • the easy formal chronological reconstruction of the operation;
  • verification of the decision-making, authorisation and implementation process, and the identification of the various levels of responsibility.

BetaGlue Therapeutics SpA complies with current legislation on taxation in order to ensure the correct determination, certification and settlement of taxes (direct and indirect).

BetaGlue Therapeutics SpA guarantees that all recipients of this Code behave in a correct, transparent and collaborative manner with the tax authorities, in compliance with the law and internal company procedures.

BetaGlue Therapeutics SpA guarantees the correct reconstruction of contractual relations and the constant control of the truthfulness of the data contained in the accounting documents.

BetaGlue Therapeutics SpA guarantees that tax returns are based on truthful accounting results and represent legitimate, existing, and correctly recorded transactions, as well as that they are signed exclusively by authorized parties.


As mentioned above, the Code is an integral part of the Management and Control Model implemented by BetaGlue Therapeutics SpA, in compliance with Legislative Decree 231/2001.

Compliance with the rules contained in the Code is an essential part of employees’ contractual obligations pursuant to and for the purposes of art. 2104 of the Italian Civil Code and must be considered an essential part of the contractual obligations assumed by non-subordinate collaborators and/or persons having business relations with the Company.

In order to ensure the effective application of the rules contained therein, BetaGlue Therapeutics SpA has adopted the following reporting channels:

Reports must be transmitted, alternatively, through the following channels:

  • to the e-mail address (password protected and compliant with data protection protocols) marked with the address indicated, which is accessed, with unique authentication credentials, only by members of the Supervisory Body;
  • by ordinary mail, to the following address: “Supervisory Body of BetaGlue Therapeutics SpA” at the Company’s registered office, in Piazzetta Umberto Giordano n.4 in Milan.

Through the aforementioned channels it is possible to:

  • seek advice on ethical and lawful behaviour and organizational integrity;
  • transmit all reports relating to any cases of non-compliance with the Code and/or the Model.

The Company’s Supervisory Body is granted the powers, duties and duties set out in the Model, to which reference should be made.

The Supervisory Body is entitled to receive requests for clarifications, complaints, or information about potential or actual violations of the Code.

In accordance with current legislation and the provisions of the Model, any information obtained in this way will be processed in compliance with the provisions described in the operational instruction for the management of “whistleblowing” and in the paragraph of the General Part of the Model, entitled “Protection of the whistleblower” to which reference should be made.


The violation of the principles of the Code of Ethics, where ascertained, compromises the Relation of trust between BetaGlue Therapeutics SpA and its directors, managers in general, consultants, collaborators in miscellaneous capacities, customers, and suppliers.

Ascertained violations of the Code, after consultation with the Supervisory Body, will give rise to specific measures. In accordance with and in compliance with the legal and contractual regulations in force, the violations ascertained may also result in the removal from the Company of the same managers.

The Company, in relation to the seriousness of the illegal activity carried out by the defendant, will take the appropriate measures, regardless of whether the Judicial Authority may prosecute. In particular, any violation of this Code, committed by employees and/or managers, will result in the adoption of disciplinary measures, proportionate in relation to the seriousness or recidivism of the fault or the degree of fault, in compliance with the discipline referred to in art. 7 of Law no. 300 of 20 May 1970 and the provisions contained in the applicable employment contracts.

The provisions of this Code also apply to temporary workers who will be required to comply with its principles. Violations of the Code are sanctioned with disciplinary measures adopted against them by the respective employment agency companies, which are required to do so on the basis of a specific contractual commitment with BetaGlue Therapeutics SpA.

With regard to the Directors and Statutory Auditors, violation of the provisions of this Code may result in the adoption, by the Board of Directors and the Board of Statutory Auditors respectively, of proportionate measures in relation to the seriousness or recurrence of the fault or the degree of fault, up to and including the revocation of the mandate for just cause to be proposed to the Shareholders’ Meeting. In the latter case, the Company is entitled to any damages suffered as a result of the unlawful conduct carried out.

With regard to suppliers, collaborators and external consultants, the violation of the principles of this Code is sanctioned with the termination of the contracts in force with them, without prejudice to the right of BetaGlue Therapeutics SpA to request compensation for damages occurred as a result of such conduct.