231 MODEL, CODE OF ETHICS

“Telespazio S.p.A., In order to ensure that everybody working for or on behalf of the Company strictly complies with laws and regulations and consistently with the principles of fairness and transparency in the management of business and corporate affairs, has adopted an Organizational , Management and Control Model (here in after also “Model”) in line with the provisions of the Italian Decree No. 231 on June 8th 2001 and based on the Guidelines issued by Confindustria (Association of Italian Industries).

A part of the application of the mentioned Decree, the adoption of such Model was decided assuming that it might represent a valid instrument for the awareness of all Company’s Directors, Statutory Auditors, employees and any other person sharing an interest in it (Clients, Suppliers, Partners, Co-workers in other capacities). They may then carry out their activities in a correct and straight forward manner, such as to prevent the risk that the crimes provided for by the Decree could be committed.

The Code of Ethics, together with the Anti-Corruption Code of Leonardo Group, is an essential part of the Model and expresses the ethical principles adopted in the management of business and operations by those working for or on behalf of Telespazio.

Telespazio shall ensure the functionality, update and continuous implementation of the Model and the Code of Ethics in application of the methodology indicated in Confindustria’s Guidelines and by the reference best practices.