Code of Ethics

1. Introduction

Deltatre’s high ethical standards are supported by our Code of Ethics, which sets out the key principles that guide our work as employees and our relationships with clients and third parties. We want to create an inclusive workspace, where we all feel safe and feel completely ourselves and respected for who they are, underpinned by healthy relationships with external stakeholders and fair competition on the market.

Please read our Code of Ethics carefully and comply with the principles set out within it. This is to protect yourself and the people you work with, by ensuring you take the right actions when faced with difficult issues.

If you have any questions, please reach out to me, the People or Legal functions, so that we can advise you accordingly.

Thank you.

Andrea Marini

CEO, Deltatre

2. The importance of the Code of Ethics for Deltatre

Deltatre is the global leader in fan-first digital experiences.

Our market-leading product and services portfolio has helped redefine the way the world consumes sport, media, and entertainment by offering specialist innovations in over-the-top streaming, websites and apps, graphics, data, officiating systems, user experience, and product design.

We are a growing community distributed in key cities around the world. At Deltatre, we recognize that we’re part of many highly influential media spaces, and we can use our privileged position to positively influence the industries we work with.

All of our staff members are required to adhere to our Code of Ethics, and to keep up to date with any changes through any additional communications and training provided by Deltatre.

3. The Purpose of our Code of Ethics

This Code of Ethics defines the key principles our staff need to follow both in their day-by-day activity and in difficult situations they may encounter within and outside the Group.

The Code is made up of a set of principles and good practices that are not exhaustive. Additional information, rules and recommendations are provided in our policies and procedures that must always be respected and read together with the Code.

The Code shall be also shared with third parties we work with to be sure that everyone understands which behaviours and actions are acceptable. We expect them to be compliant with these principles that represent our Group and the standards that need to be followed.

4. Zero Tolerance

In our Group we do not tolerate any form of bribery or corruption.

Bribery is defined as giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so. It could cover seeking to influence a decision-maker by giving some kind of extra benefit (for example a gift, money, hospitality) to that decision-maker rather than by what can legitimately be offered as part of a tender process or otherwise.

All persons working for or on behalf of the Company in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third party representatives and business partners are expressly prohibited from offering or providing any gifts or inducements and are responsible for maintaining the highest standards of business conduct.

5. Conflict of Interests

A Conflict of Interest is a situation in which an employee has a vested interest (such as money, status, knowledge, relationship) which may interfere in a business decision or process by an influencing, impartial and objective exercise of their functions.

In our Group, we require our staff to preliminarily inform their line manager not to be in an actual, potential, or perceived conflict of interest situation. When someone finds themselves to be in that situation, we provide support and advice to assess the risk and, when necessary, manage and/or mitigate it.

6. Fair Competition

Fair competition is fundamental in an open-market economy since it is the pre-requisite for doing business according to the highest standards by creating and maintaining an equal level playing field.

Our staff must not undertake any action that could unfairly exclude or reduce competition in any market. We are required not to misrepresent, manipulate, conceal, misuse confidential information, and to not engage in disparaging discourse against competitors, or unfair practices with shareholders, clients, business partners, competitors, and other employees. The information about competitors, their products, services, technologies, pricing, marketing campaigns, etc. must be obtained only through legal and ethical means.

Deltatre also pays great attention to the way it treats information exchanged with third parties. We never directly or indirectly exchange commercially sensitive information with competitors except where such exchanges are strictly in accordance with all applicable laws and regulations.

7. Correct Use of Group Assets

Our Group has many valuable assets. They can be physical, tangible goods, such as: vehicles, real estate, computers, office furniture, and other fixtures, or intangible items, such as: intellectual property, information data or code.

Everyone in Deltatre is responsible for exercising good judgment regarding appropriate use of the Company assets in accordance with the other relevant Group policies and standards, and local laws and regulations.

8. Protection of Confidential and Privileged Information

Protection of information is of utmost importance, as it also deals with the concept of conducting business in good faith and according to the highest standard of business to which our Group has always adhered to.

We have outlined in detail how to protect the security of our systems and information when being shared or exchanged both internally and externally.

Our staff has the duty to classify and secure the information and to put in action the appropriate controls where necessary.

Deltatre’s clients and the general public can expect that we protect the confidentiality of the information we own, or make available during business operations, and that we promote and share only reliable information.

9. Data Protection

As a Group we pay the utmost attention when processing personal information both of our staff members and of our clients. Data protection is one of our priorities and we always act in compliance with applicable laws, regulations and best practices also following the guidelines of the relevant data protection authorities.

We have implemented our privacy model considering the different geographies in which we work and deal with, and constantly supervise their compliance to the relevant laws.

We have a dedicated team that works at a global level, assessing the various implications from a legal, compliance, IT and cyber perspective.

Our staff are required to strictly observe the data protection policies adopted and are duly trained on the best practices that must be followed in our day-to-day business activities.

10. Safety of Workplace

We ensure safe and hygienic conditions for all our staff and third parties, and we work to always guarantee the highest standards in that respect.

Deltatre acts in accordance with the relevant applicable laws and regulations and also has the ability to promptly react in case of a public emergency declared by the World Health Organization, such as pandemics.

In these cases, specific hygienic protocols are ready to be put in place and enforced along with a dedicated internal committee that is able to constantly monitor the effectiveness of the measures put in place.

In our Group, the safety of our staff and of any third party we may come into contact with is a priority in every circumstance.

11. Our Commitment to Human Rights

We are committed to ensuring that there is no slavery, servitude, forced or compulsory human labor, abuse of power over vulnerable individuals, human trafficking, or any other form of exploitation in any part of our business or in our supply chain.

Our policies and procedures reflect our constant commitment towards the highest set of ethics and values that guide our governance and daily management decisions.

We recognize that we must be a profitable business, endeavoring to consistently operate above and beyond existing ethical and legal standards.

As an organization, we are committed to expanding our operations globally in a sustainable manner for the benefit of our clients, our employees, and the wider communities and environments on which our business impacts. The business takes a pro-active approach to its corporate responsibility, which is deeply rooted in its corporate strategy and business decisions.

In accordance with our constant commitment to acting ethically and with integrity in all our business relationships, we have implemented effective systems and controls to ensure that fundamental human rights are always respected in our Group.

12. Equality, Diversity and Inclusion

We think that an inclusive work environment is fundamental. The power of innovation and excellence comes from drawing talent, ideas, and contributions from as wide a pool of people as possible – both in terms of our community within Deltatre, and from our partners and customers.

We strongly believe in diversity in the workplace, and we are working hard to understand and celebrate the attributes and characteristics of our people worldwide.

Our commitment to maintaining an inclusive workplace is continuous. We want everyone to feel completely themselves and respected for who they are. In our Group, everyone is welcome and celebrated.

13. Environmental, Social and Governance (ESG)

We acknowledge the climate emergency, and we are therefore committed to reducing our environmental impact and continually improving our environmental performance.

This forms an integral part of our business strategy and operating methods, and we are willing to make necessary improvements to have a positive impact on our industry and on the clients we work with.

We believe this is a shared responsibility and have thus issued best practice guidelines, policies and procedures for our global team and stakeholders to ensure that the aims and objectives are fully supported.

Our focus is also to ensure that we are aware and compliant in environmental legislation and other voluntary obligations that are relevant to our business and climate change mitigation.

14. Whistleblowing System

We are committed to conducting business with honesty and integrity and expect all those working within it to maintain high standards.

All organizations, however, face the risk of things going wrong from time to time, or of unknowingly harboring illegal or unethical conduct. A culture of openness and accountability is essential to prevent such situations occurring and to address them if they do occur.

We then encourage a culture where people feel free to speak up so that any possible wrongdoing can be addressed quickly.

We have implemented whistleblowing processes according to the applicable local laws and made available dedicated channels to report the issues.

Both who raises the concern and the person targeted shall benefit from the strictest confidentiality. Anonymous reports are admitted and considered where this is permitted by local law.

Deltatre will support those who raise genuine concerns, in good faith, even if they turn out to be mistaken.

Further information on our whistleblowing systems can be found in Deltatre Connect, in the HR section.

15. Artificial Intelligence In Deltatre

As a company, we recognize the huge upsides and impacts the adoption of AI are having and will have on our industry, and we are committed to implementing it to enhance efficiency and provide innovative solutions. However, we acknowledge the importance of caution, particularly in ensuring ethical and responsible AI practices.

We strive to avoid discrimination paying attention to act always in a fair and transparent way.

Also, we integrate AI sustainably, considering also social impacts of it.

Our ethical standards are always maintained, and, with respect to the AI, we constantly promote a positive contribution to the business and the society.

Striking a balance between technological advancements and ethical considerations is paramount to guaranteeing the positive impact of AI within our operations, processes and products.

16. Applicability of the Code of Ethics

All of our staff members are responsible for adhering to the Code of Ethics in every circumstance, throughout the duration of their employment with Deltatre.

Any breaches of staff's obligations or prohibitions set out in the Code of Ethics may give rise to disciplinary sanctions and/or actions in accordance with the relevant disciplinary policies as set forth in the internal rules, where applicable, and/or local law.