0.1 Objectives
The Company C.C.D.F. S.p.A. is aware of contributing with its work, with a sense of responsibility and moral integrity, to the development process of the Italian economy and civil growth of the country. The Company believes in the value of work and considers that legal, fair and transparency actions are essential prerequisites to achieve its economic, productive, and social goals.

0.2 Adoption
This Code of Ethics and the following Organisation, Management and Control Model were adopted by the Company by resolution of the Board on 05.12.2008.
Through the adoption of the Code, the Company has set the following rules:

- of conduct in relations with external stakeholders, employees, and the market and
environment, under which the Company conducts its internal and external activities, requiring compliance by all employees, consultants and external stakeholders;
- of Organization and management of the Company, aimed at creating an efficient and effective planning, execution and control of activities that ensure full compliance with the rules of conduct and to prevent the violation by any person acting on behalf of the ' company.

0.3 Dissemination
The Code shall be widely distributed internally and is available to any party within the
Company. A copy of the Code is published on the company website.
Each employee of the Company is required to know and comply with the provisions of the Code, the Company carefully monitors compliance with the Code by providing suitable information, prevention and control, and intervening, where appropriate, with corrective actions.

0.4 Update
The Code can be amended and supplemented, by decision of the Board of the Company, on the basis of the suggestions and guidance from the Control Comittee.
PART I - RULES OF CONDUCT
A. Section I - External relations

1.1 Competition
The Company believes in fair and free competition and informs its actions to obtain competitive results that reward skills, experience and efficiency. The Company and its employees must use appropriate conduct in the affairs of the enterprise and interest in relations with the Public Administration.
Any action aimed at changing the conditions for adequate competition is contrary to company policy and is prohibited to any person who acts for works for the company.
In any case, the pursuit of the interests of the Company may justify the conduct of directors or employees of the Company that fails to comply with applicable laws and in accordance with the rules of this Code. In any communication with the outside information about the company and its activities must be truthful, clear, verifiable.
1.2 REPORTS
1.2.1 With clients
The reports of the Company with any other party, public or private, must be conducted in accordance with law and in accordance with the principles of fairness, transparency and verifiability. In particular, relations with civil servants must be in accordance with the principles and provisions dictated by the DPCM November 28, 2000 (Code of Conduct for government employees).
Any form of gifts that canappear as exceeding normal commercial practice or courtesy, or aimed at obtaining favorable treatment in the conduct of any business are not permitted.
With respect to employees or representatives of public administrations have banned seeking and the establishing of personal relationships for favorable influence is forbidden, interference likely to affect, directly or indirectly, the outcome of the report, are also prohibited offers of goods or other utility representatives, officers or employees of public administration, through nominees, except in the case of gifts of modest value and conform to the uses and can not always be understood as aimed at seeking undue favors. The Company does not make contributions, benefits or other benefits to political parties and trade unions, or to their representatives, if not in compliance with applicable regulations.

.2 REPORTS
1.2.1 With Clients
The reports of the Company with any party, public or private, must be conducted in accordance with law and in accordance with the principles of fairness, transparency and verifiability. In particular, relations with civil servants must be in accordance with the principles and provisions dictated by the DPCM November 28, 2000 (Code of Conduct for government employees).
It is not allowed any form of gift that can only appear as exceeding normal commercial practice or courtesy, or aimed at obtaining favorable treatment in the conduct of any business.
Against employees or representatives of public administrations have banned research and the establishment of personal relationships on favorable influence, interference likely to affect, directly or indirectly, the outcome of the report, are also prohibited offers of goods or other utility representatives, officers or employees of public administration, through nominees, except in the case of gifts of modest value and conform to the uses and can not always be understood as aimed at seeking undue favors. The Company does not make contributions, benefits or other benefits to political parties and trade unions, or to their representatives, if not in compliance with applicable regulations.
1.2.2 WITH CUSTOMERS AND CLIENTS
The company bases its activities on the criterion of quality, intended primarily as a goal of full customer satisfaction. In relations with the operators of the shopping center which the Company owns and operates, the company ensures fairness and transparency in trade negotiations and in the assumption of contractual obligations, and the faithful and diligent contact fulfillment. The company resorts to litigation only when his legitimate claims are meet with due satisfaction. When conducting any negotiation situations in which those involved in the transaction are, or may appear to have a conflict of interest, must always be avoided.

1.2.3 WITH SUPPLIERS
Relationships with Company suppliers, including financial and consulting contracts are governed by the provisions of this Code and are subject to constant and careful monitoring by the Company.
The Company uses suppliers, contractors or subcontractors who are in compliance with local regulations and rules provided in this Code.

1.3 ENVIRONMENT
The production activities of the Company shall be managed in compliance with existing environmental legislation. When it promotes, designs or entrusts the design of construction projects, the Company makes sure or takes care that, among other things, all studies necessary to verify the possible environmental risks arising from the intervention and prevention of the damage are carried out.
The Company is committed to promoting and consolidating among all employees and subcontractors a culture of environmental protection and pollution prevention, raising awareness of the risks and promoting responsible behavior by all employees.


B. Section II - RELATIONS WITH EMPLOYEES

2.1 Work
The Company recognizes the centrality of human resources as the main factor of success of any business, in a context of fairness and trust between employer and employee. The company promotes the continuous improvement of the professionalism of its employees.

2.2 Safety and Health
The Company garantees the physical and moral integrity of its employees, working conditions that respect the dignity of the individual and a safe and healthy workplace, in full compliance with current regulations on the prevention of accidents and protection of workers in the workplace, including temporary and mobile construction sites.
The Company conducts its activities in the technical, organizational and economic conditions tha insure adequate accident prevention and a healthy and safe working environment. The Company is committed to promoting and consolidating among all employees and subcontractors a safety culture, developing awareness of the risks and promoting responsible behavior by all.


PART II - RULES 'OF IMPLEMENTATION

3.1 Prevention
In accordance with local regulations and with regard to planning and management of corporate activities aimed at efficiency, fairness, transparency and quality, the Company shall take appropriate organizational and management measures to prevent unlawful behavior or behavior otherwise contrary to the rules of this Code by any person acting for the Company. Because of the joint activities, the company adopts a system of delegation of powers and functions, providing in explicit and specific terms the allocation of tasks to people with suitable skills and expertise.
In relation to the extension of delegated powers, the Company adopts and implements organizational and management models that provide for appropriate measures to ensure that activities are conducted respectubg the law and rules of behavior of this Code, and to discover and remove promptly any at risk situations.

3.2 Controls
The Company adopts specific procedures for verifying the conformity of behavior for anyone acting on behalf of the company or in its scope to the provisions of current legislation and rules of behavior of this Code.

3.3 Sanctions
The observance by all employees of the Company of the Code is an essential part of the contractual obligations pursuant to art. 2104 Civil Code The violation of the Code by employees may constitute failure in the primary obligations of the partnership, with all legal consequences.