The present Code of Ethics, approved by the Board of Directors of the Ravenna Football Club 1913 S.p.A., is an integral and substantial part of the Organization, Management, and Control Model pursuant to Legislative Decree 231/2001 of the aforementioned company.

It contains general ethical values that, together with legal, regulatory, and contractual provisions, represent guidelines that must be translated into behavioral principles and control protocols presented in the Special Parts of the Model.

Ravenna Football Club 1913 S.p.A. recognizes that adherence to behavioral principles based on ethical values is of fundamental importance for its sporting, economic, and reputational growth.

The Club believes in the importance of the social function of sport in general and, in particular, of football as a tool for training, education, integration, and the aggregation of individuals. In carrying out its activities, the Club acknowledges and promotes the values enshrined in the regulations issued by sports institutions such as CONI, FIGC, FIFA, and UEFA.

The Club aims to set an example of loyalty, fairness, and integrity in the football world and is therefore committed to safeguarding and developing its image and reputation—through the promotion and participation in initiatives related to solidarity, training, and social integration—and expects the same commitment from its personnel.

Aware of the importance that the behavior of players, coaches, assistants, managers, and all staff, in general, holds in shaping its image, the Club requires that these individuals maintain ethically and professionally impeccable conduct at all times. In return, the Club commits to fully respecting the personality and professionalism of its collaborators, promoting mutual respect, and rejecting any behavior that could potentially harm the dignity of individuals.

Professional players represent the public face of Ravenna Football Club 1913 S.p.A. and, therefore, are expected to help disseminate the values the Club upholds. They serve as role models for future generations and are in the public eye, pledging to respect and promote the Club’s values with impeccable behavior on and off the field. This implies that any statements made—whether in official media interviews or privately via social media—should be carefully considered, bearing in mind their potential impact on fans and the public.

Furthermore, players serve as a point of reference and inspiration for young individuals entering the world of football and must provide a morally and humanly impeccable example to follow.

The Club, aware that the growth of its players is above all a fundamental tool for education and development, as well as a valuable resource, pays special attention to the proper management and organization of the youth sector, particularly concerning the moral and educational obligations of coaches, trainers, and all those involved in activities that require close contact with young players.

Youth football activities are organized to ensure that the facilities and staff dedicated to competitive and non-competitive activities are appropriate to the specific needs of young players.

In particular, the Club educates young players on the values of friendship and mutual respect towards teammates and opponents, promoting fair play, a fundamental and essential value that must guide the competitive activities of all the Club's teams.

The Club ensures that competitive activities are conducted in accordance with the rules, rejecting any behavior that could potentially alter or disrupt the normal course of competition and the regularity of results, and categorically rejects any form of betting related to such activities.

Additionally, the Club guarantees the implementation of appropriate measures to prevent players, managers, and all other registered members from engaging in online gambling and/or practicing any form of gambling, such as poker, slot machines, etc.

The Club is actively committed to fighting doping and combating all forms of physical and verbal violence, exploitation, abuse, and harassment. Therefore, the Club opposes all discrimination based on personal or cultural differences, gender, race, religion, sexual orientation, and beliefs. It also strongly condemns any statements that constitute territorial or ethnic discrimination.

The Club condemns all forms of violence, both on and off the field.

Players, whether from the professional sector or not, must show respect for opponents and the rules, avoiding the simulation of fouls or provocations towards opponents.

The principle of non-violence and the fight against discriminatory behavior must be shared and promoted in relations with the Club's fans. Therefore, players, coaches, and managers must avoid inciting violent or aggressive acts and promote healthy, non-discriminatory, or otherwise offensive support toward opposing players or fans.

For these reasons, the Club is actively involved in promoting events and initiatives against violence and discrimination through the organization of activities, interventions, and public meetings with professional players, managers, and sports technicians aimed at raising awareness among fans and the general public.

The Club is also present in the community with initiatives aimed at preventing the abuse of alcohol, drugs, and performance-enhancing drugs, particularly when their use is intended to enhance sports performance.

The Club commits to complying with the regulations and directives issued by CONI, FIGC, FIFA, UEFA, and their bodies and to fostering a corporate culture inspired by principles of fairness and good faith in competitive activities and relations with external parties. To ensure this, the establishment of an internal control system involving all corporate functions is essential to ensure compliance with regulations and corporate procedures.

The Code of Ethics (hereinafter also referred to as the "Code") has been developed to translate ethical values into principles of conduct, which its recipients are required to follow in conducting business and their activities.

The ethical principles of conduct contained in this document therefore characterize the Club's activities and guide the corporate organization, providing programmatic indications of a binding nature.

The Club's decision is to complement broader and more general ethical values with a set of ethical principles that better respond to the specific requirements contained in Legislative Decree 231/2001 and in Article 7, Paragraph 5, of the FIGC Statute.

This Code of Ethics is inspired by the moral and social values of FIGC and the League to which the sports club belongs, and it conforms to the principles indicated by the IOC, CONI, FIFA, UEFA, FIGC, and the Italian Professional Football League. It aims to be an instrument for achieving respect and ethical, moral, and social discipline.

The Code of Ethics of **Ravenna Football Club 1913 S.p.A.** is binding and must be observed by:

1) the administrators and managers of the Club (so-called "top-level subjects");

2) employees and registered members (so-called "internal subjects under the direction of others");

By specific acceptance or by virtue of specific contractual clauses, the following external subjects (hereinafter the "External Subjects") may also be bound by specific obligations for compliance with the contents of the Code of Ethics:

a) sports agents of the players;

b) collaborators, consultants, and generally those who perform freelance activities;

c) suppliers and partners (also in the form of temporary business associations, including employment agencies as well as joint ventures) to the extent that they act on behalf of or in the interest of the Club in the areas of activity identified as sensitive within the Organization, Management, and Control Model.

This Code of Ethics must be accepted by ticketing companies, which must make explicit reference on the ticket to the stadium’s terms of use, this Code, and the Code governing the transfer of access tickets to football events.

Additionally, this Code of Ethics applies to fans and all those who purchase tickets to football events organized by the Club and, after their first ticket purchase and thereby acceptance of this Code of Ethics, attend team training sessions or friendly matches organized by the Club.

Respecting the principles contained within the Code of Ethics is a moral duty for all recipients in order to pursue the Club’s objectives according to the fundamental values of integrity, transparency, legality, impartiality, and prudence, in full compliance with national and international regulations.

In particular, the recipients are required to:

- align their behavior with the provisions of the Code of Ethics;

- immediately inform the Supervisory Body of any violations of ethical behavior principles as soon as they become aware of them;

- request interpretations or clarifications regarding the ethical behavior principles defined herein, if necessary.

All recipients of the Code of Ethics are required to observe and respect its principles and reference values, as well as to adhere to the behavioral standards contained therein. Knowledge of and compliance with the provisions of the Code represent an essential requirement for establishing and maintaining collaborative relationships with third parties and for maintaining relationships with fans, to whom the sports club is committed to providing all related information.

The sports club Ravenna Football Club 1913 S.p.A. considers equal treatment as a fundamental value in all internal and external relations.

All individuals involved and operating within the sports club are required to comply with laws, regulations, and federal directives and must conduct themselves according to principles of fairness, honesty, and integrity in every relationship connected to sporting activities.

These principles form the basis of the behavioral standards outlined in the Code of Ethics; therefore, any action or objective pursued by Ravenna Football Club 1913 S.p.A. must not contradict these standards.

The set of tools and processes necessary or useful to direct, manage, and monitor the activities of Ravenna Football Club 1913 S.p.A. is aimed at ensuring with reasonable certainty: the achievement of objectives; the adoption of behaviors and processes that guarantee compliance with current regulations and conformity to the principles of the League to which the sports club is affiliated; the reliability and accuracy of information, including accounting and financial data, that circulates within the club or must be disclosed to the League, the FIGC, and third parties; and the confidentiality of corporate information that has not been made public.

All recipients of the Code of Ethics of Ravenna Football Club 1913 S.p.A. have the opportunity to report and/or signal to the Supervisory Body those behaviors that, as described in the following articles, they believe to be in violation of the present Code of Ethics. Ravenna Football Club 1913 S.p.A. does not tolerate any form of retaliation against employees who make good faith reports. Every report must be handled with the utmost confidentiality.

The Board of Directors/Single Director of the sports club will report to the Supervisory Body any facts and incidents that are in violation of the provisions of this Code of Ethics.

1.1 The recipients of the Code of Ethics commit to ensuring, in the conduct of competitive activities and those preparatory and organizational activities, the strict adherence to Olympic values.

1.2 These values encompass the concepts of friendship, respect for others, and sportsmanship. They include the fight against any practices that distort or undermine the rules, against doping, match-fixing, violence (both physical and verbal), abuse and harassment, racial discrimination, exploitation, inequality in youth opportunities, corruption, and the distortive commercialization of sports values.

2.1 The recipients of the Code of Ethics commit to observing, without evasion or circumvention, and correctly interpreting in their true value and meaning both the laws of the Republic and all regulations issued by national and international sports institutions, with particular attention to those adopted by FIGC and Lega Pro.

2.2 The recipients of the Code of Ethics commit to promoting conduct of utmost active vigilance to prevent and promptly report any behavior that undermines sportsmanship, any illegal activity, or any risk of criminal infiltration within the operational scope of the sports club.

3.1 The recipients of the Code of Ethics commit to supporting, through honest cooperation with public institutions at all territorial levels and sports institutions, particularly FIGC and Lega Pro, the effective and efficient application of laws, directives, regulations, or measures issued by such institutions in all legal and economic matters related to sports, and specifically to football. They also commit to ensuring full execution, without reservations or objections—except for legitimate appeal procedures—of the decisions made by sports justice bodies.

4.1 The recipients of the Code of Ethics commit to conducting themselves with the highest level of mutual fairness in both competitive and administrative relationships, adhering to all common practices of sports and financial fair play.

4.2 They also commit to pursuing legitimate competitive results in strict compliance with the rules, rejecting and reporting any practices that might, even potentially, alter the normality and truth of the sports result.

4.3 They thus commit to rejecting and reporting the practice of doping.

4.4 They commit to rejecting and immediately reporting any possible contact/discussion/information aimed at altering sports performance or competitive results, especially when related to sports betting; each recipient of this Code thus undertakes to actively participate in the fight against match-fixing, considering such illicit practices as undermining the very roots of sports.

4.5 In line with this commitment, recipients cannot participate in sports contests or bets, either directly or indirectly, concerning football matches nor accept gifts, favors, or benefits. They also have the obligation to immediately report any form of recommendation or invitation aimed at influencing the free formation of sports results as expressed on the field of play.

4.6 The sports organization, in conformity with the principles of its affiliated league and sports institutions, commits to promoting internally and participating in all initiatives aimed at preventing sports frauds of any kind (e.g., betting, illicit agreements, and doping), and aimed at ensuring the fair and honest conduct of the competitions in which the sports organization participates.

4.7 The sports organization considers its own image and reputation, along with the reputation of its affiliated league, as values that must be protected and developed through the full dissemination, sharing, and adherence to the ethical principles of sportsmanship and fairness contained in this Code. Recipients must refrain from behaviors, both public and private, that may harm the image of the sports organization and its affiliated league, and must work to uphold the same.

5.1 Recipients of the Code of Ethics commit to diligently and responsibly respecting the physical, moral, and cultural integrity of individuals in the performance of competitive, preparatory, and organizational activities. Conduct that systematically offends this integrity, such as cyberbullying, is deemed harmful.

5.2 Ravenna Football Club 1913 S.p.A. is committed to promoting working conditions and environments that protect the psycho-physical integrity of individuals and encourage proactivity, creativity, active participation, teamwork, and accountability. The Sports Organization commits to participating in, promoting, and implementing initiatives aimed at safeguarding the health of its athletes and staff.

5.3 Recipients of the Code of Ethics must not engage in or make statements that could incite violence. The Sports Organization is committed to undertaking all necessary activities and initiatives to raise awareness among its supporters, combat phenomena that incite violence, promote gender violence awareness, and address any other forms of violence related to its football competitions.

5.4 Sports organizations and their officials must ensure that sports activities are conducted with respect for individual dignity, in safe environments free from external and social dangers. They must also monitor their registered athletes to prevent the use of doping practices.

5.5 Sports organizations must promote and safeguard the technical and sporting development of young professional athletes and support their continued educational pursuits. They should also advocate for a culture of respect for opponents and promote initiatives to foster respect among supporters.

5.6 Within the sports organization, professional development and management of employees and collaborators are based on the principle of equal opportunity. The organization is committed to providing its employees, collaborators, and staff with the necessary tools for effective professional growth.

5.7 Recipients of the Code of Ethics, including officials, medical, and paramedical staff, must ensure the protection of athletes' personal data, especially health-related information, recognizing privacy as a fundamental right and a pillar of individual freedom and dignity, and as a prerequisite for proper sports conduct.

5.8 While maintaining the principle of athletic and technical discipline in relations between sports organizations, officials, coaches, athletes, and all recipients of the Code of Ethics must refrain from invasive monitoring of individuals' private lives.

5.9 Applicable principles from general legal regulations, sports regulations, and provisions from the National Authority for the Protection of Personal Data are reiterated, as applicable to the sports context.

5.1 Recipients of the Code of Ethics are committed to diligently and responsibly respecting the physical, moral, and cultural integrity of individuals in all competitive, preparatory, and organizational activities. Conduct that systematically offends this integrity, such as cyberbullying, is considered harmful.

5.2 Ravenna Football Club 1913 S.p.A. is committed to promoting working conditions and environments that protect the psycho-physical integrity of individuals and encourage proactivity, creativity, active participation, teamwork, and accountability. The Club will participate in, promote, and implement initiatives aimed at safeguarding the health of its athletes and staff.

5.3 Recipients of the Code of Ethics must not engage in or make statements that could incite violence. The Club will undertake all necessary activities and initiatives to raise awareness among its supporters, combat phenomena that incite violence or offenses, promote awareness campaigns against gender violence, and address any other forms of violence related to its football competitions.

5.4 Sports organizations and their officials must ensure that sports activities are conducted with respect for individual dignity, in safe environments free from external and social dangers. They must also monitor their registered athletes to prevent the use of doping practices.

5.5 Sports organizations must promote and protect the technical and sporting development of young professional athletes and support their ongoing educational pursuits. They should also advocate for a culture of respect for opponents and promote initiatives to foster respect among supporters.

5.6 Within the sports organization, professional development and management of employees and collaborators are based on the principle of equal opportunity. The organization is committed to providing its employees, collaborators, and staff with the necessary tools for effective professional growth.

5.7 Recipients of the Code of Ethics, including officials, medical, and paramedical staff, must ensure the protection of athletes' personal data, especially health-related information, recognizing privacy as a fundamental right and a pillar of individual freedom and dignity, and as a prerequisite for proper sports conduct.

5.8 While maintaining the principle of athletic and technical discipline in relations between sports organizations, officials, coaches, athletes, and all recipients of the Code of Ethics must refrain from invasive monitoring of individuals' private lives.

5.9 Applicable principles from general legal regulations, sports regulations, and provisions from the National Authority for the Protection of Personal Data are reiterated as applicable to the sports context.

6.1 To protect the principles outlined in the previous Article 5, Paragraph 9, Ravenna Football Club 1913 S.p.A. prioritizes the protection of personal data, both to prevent unauthorized or unlawful processing of data in its possession and to avoid accidental damage, destruction, or loss of such data.

6.2 Regarding the handling of confidential and privileged information, Recipients who, by virtue of their office, become aware of:

- confidential information of the sports club;

- confidential and sensitive information from public authorities;

- confidential information about the sports club’s registered members;

- confidential/sensitive information related to fan “approval”;

have a duty not to disclose such information to other associates of the affiliated League (or to another League or sports organization due to contractual relations for the transfer/valorization of registered members) and to third parties, except for official or professional reasons, and always in full compliance with current regulations and internal rules. Recipients are also required not to use such information for any purpose other than the intended work-related purposes and, in any case, in accordance with laws and regulations.

6.3 When communicating with third parties, the confidential nature of the transmitted information and the obligation of confidentiality on the part of the third party must be declared.

6.4 The internal circulation of documents related to confidential information, as well as their circulation to other sports organizations, the affiliated League, and third parties, must be carefully managed, keeping the number of informed individuals to a minimum to avoid prejudicing the sports club and unauthorized disclosures.

6.5 Recipients are required not to disclose news or measures learned in the course of any relations with the affiliated League, in their role as Board Member, if such information has not already been formalized and communicated to the relevant parties and institutions.

6.6 Regarding the protection of personal data, pursuant to Legislative Decree No. 196/2003, “personal data” is defined as any information relating to a natural or legal person, entity, or association, identified or identifiable, even indirectly, by reference to any other information, including a personal identification number.

6.7 To ensure the protection of personal data concerning individuals interfacing with Ravenna Football Club 1913 S.p.A., the Club commits to processing such data in compliance with applicable regulations and, in particular, according to the following criteria:

- Transparency towards the data subjects: individuals have the right to know what personal information is collected, for what purposes, and whether it is disclosed;

- Lawfulness and fairness of the processing;

- Relevance of the processing to the stated and pursued purposes, meaning that personal data will not be used for secondary purposes without the consent of the data subject (unless legally required);

- Disclosure of data to third parties cannot occur without the consent of the data subject (except where required by law);

- Guarantee of the quality and accuracy of the data.

7.1 Aware of the social and cultural role of sports in Italy—particularly football—Recipients of the Code of Ethics are committed to responsible behaviors towards the entire sports community, with particular attention to the world of supporting spectators.

7.2 Such behaviors should be realized through:

- **Economic Conduct**: Ensuring exemplary financial management that guarantees the continuity of the organization within its territorial context.

- **Transparency**: Absolute transparency in communicating to the public data related to the technical-sporting and economic aspects of the organization, and immediate reporting of any attempts at illegal activities from any source.

- **Friendly Conduct**: Building positive relationships with families, educational institutions, youth, and their associations, avoiding any discrimination based on age, gender, religious orientation, and nationality.

- **Welcoming Media Relations**: Engaging amicably with the media in their legitimate role of information, maintaining a proper constitutional balance between the right to report and the protection of privacy.

8.1 In recognition of the social and cultural role of sports in Italy—particularly football—Recipients of the Code of Ethics are committed to upholding the reputation and image of CONI, FIGC, the relevant League, associated teams, and all individuals involved in organizing competitions.

8.2 In relations with institutions and public officials, Recipients must conduct themselves transparently and with utmost fairness and cooperation. No Recipient may promise or give money or other benefits to public officials personally to promote or favor the interests of Ravenna Football Club 1913 spa, even under illegal pressure. No Recipient can circumvent these requirements by using alternative forms of aid or contributions disguised as sponsorships, contracts, consultancy, advertising, etc., with the same prohibited aims.

8.3 Subject to the principles of legality and honesty, Recipients must thoroughly verify the accuracy and truthfulness of data and information in declarations or communications to public administrations or institutions, including the relevant League.

8.4 It is prohibited to exert any form of pressure on individuals required to make statements before the judicial authority (which constitutes the crime described in Article 377 of the Italian Penal Code and is thus punishable) or sports justice organs to induce them to refrain from making statements or to make false statements.

8.5 In dealings with sports regulatory bodies (FIGC, CO.VI.SOC, CONI) and state bodies (Data Protection Authority, AGCOM, Antitrust Authority, etc.) or investigations (public safety, judicial, tax, health authorities, etc.), the sports organization supports its activities organizationally and documentarily, facilitating proper inspections.

8.6 External collaborators of the sports organization are required to observe the ethical principles and behavioral rules set out in this Code of Ethics.

8.7 All Recipients, in relation to their duties, must:

- Follow internal procedures for managing relationships with external collaborators;

- Select only counterparties with appropriate professional qualifications and reputations;

- Apply contractually agreed conditions, ensuring that compensation is solely based on the contractually specified services and payments are made only to the contractual counterparty;

- Require external collaborators to adhere to the principles of this Code and include a specific obligation in contracts to comply with these principles;

- Promptly report any behavior by external collaborators that appears contrary to the ethical principles or rules of the Code.

8.8 **Relations with Partners**: Given the modern complexity of organizing football events and commercializing advertising spaces, other parties or partners may be involved through agreements or partnerships.

8.9 In developing these initiatives, all partners must adhere to the ethical principles outlined in this Code. Recipients must:

- Engage only with partners or other parties who have a respectable reputation, are involved in lawful activities, and adhere to ethical principles comparable to those of the sports organization and the relevant League;

- Ensure no partner receives unfavorable or penalizing treatment compared to their contribution;

- Guarantee equal treatment for all participants in negotiations;

- Ensure transparency in agreements and avoid signing secret or illegal agreements;

- Report promptly any partner or associate behavior that appears contrary to the principles, values, and rules of the Code.

8.10 **Relations with the Press**: Interactions with the press are handled exclusively by designated functions and are characterized by correctness, transparency, and impartiality. Recipients are not permitted to make statements or issue communications that could harm the image of the sports organization, its members, or those involved in its sports activities, as well as the image of the relevant League.

8.11 **Internal Control System**: The sports organization considers establishing an adequate control environment, aligned with the ethical and financial principles of the relevant League, as a key element of its organization. This contributes to improving the efficiency and effectiveness of the organization's activities, and Recipients must be appropriately informed.

8.12 **Accounting Transparency**: The sports organization acknowledges the importance of transparency, accuracy, and completeness in accounting information and strives to maintain a reliable administrative-accounting system that accurately represents management facts and provides tools to identify, prevent, and manage financial and operational risks and fraud.

8.13 Accounting records and related documents must be based on precise, comprehensive, and verifiable information, reflecting the nature of the operation and complying with external regulations (legal norms, accounting principles) and internal policies, plans, regulations, and procedures. They must also be accompanied by necessary supporting documentation for objective analysis and verification. Accounting records must allow:

- Production of accurate economic and financial statements (balance sheets, informational documents, etc.);

- Demonstration of the correctness and transparency of operations related to the distribution of broadcasting rights revenue, as regulated by current legislation and assembly resolutions;

- Provision of tools to identify, prevent, and manage financial and operational risks and fraud, including the use of public funds;

- Execution of controls to reasonably ensure the protection of asset value and prevention of losses.

8.14 All Recipients of the Code are therefore required to:

- Ensure that management facts are accurately and timely represented, allowing the administrative-accounting system to achieve the aforementioned objectives;

- Ensure that information and documents requested by the Board of Auditors are promptly prepared in accordance with the principles of this Code and the provisions of the Model of Organization, Management, and Control adopted by Lega Pro.

8.15 The same principles and behavioral rules will be adopted by Lega Pro in necessary interventions to regulate the administrative and financial management of member clubs to ensure proper management and safeguard the integrity of competitive activities.

8.16 All Recipients of this Code are aware of the management model under Law 231 adopted by the sports organization and are committed to adhering to the procedures provided and taking all necessary precautions to prevent any violations.

8.17 Recipients, in actions or operations performed on behalf of or for Ravenna Football Club 1913 spa, must act with diligence, responsibility, and professionalism, making the best use of available resources and time, and assuming responsibility for their actions or omissions.

9.1 **Conflict of Interest**: All Recipients must ensure that every decision is made solely in the interest of the sports organization. They must avoid any situation where personal economic activities could conflict with their duties within the sports organization, potentially compromising their independence of judgment and choice. Those appointed to positions within the sports organization must carry out their mandate exclusively in the interest of the organization.

10.1 **Adherence to League Code of Ethics**: The sports organization affiliated with the League commits to adhere to and respect all principles and conduct standards outlined in the League's Code of Ethics for the registration of Directors, coaches, or athletes.

10.2 **Evaluation and Interpretation**: The principles and rules of the Code of Ethics serve as a standard for evaluating and interpreting the legality of the conduct of Recipients, both in the context of complaints and in determining the sanctions imposed by the sports regulations.

10.3 **Scope of the Code**: This Code does not exhaustively list all ethically sensitive behaviors. It provides a general typology which does not preclude the possibility that the Supervisory Body may identify other conduct that, while not constituting a crime, still violates the general principles stated in the Code.

11.1 **Transparency in Donations and Sponsorships**: In carrying out charitable activities, sponsorships, and organizing events for charitable purposes, the sports organization adopts the highest standards of transparency and fairness in managing these activities.

13.1 **Disciplinary and Sanctioning System**: Violations of the Code of Ethics and the normative and regulatory provisions it refers to are subject to the disciplinary and sanctioning measures outlined in the General Part of the Organization, Management, and Control Model adopted by the Company pursuant to Legislative Decree No. 231/01, regardless of whether a criminal proceeding has been initiated or its outcome.

Article 14 Principles of Legality and Honorability

14.1 **Compliance with Legal Framework**: The sports club, as a legal entity organized in the form of a capital company, operates in strict compliance with national and European legislation, continuously and thoroughly overseeing every sector and function of the organizational structure and all corporate bodies.

14.2 **Selection Criteria for Corporate Positions**: The Club selects candidates for corporate positions from individuals who possess, in addition to recognized professional, operational, and sports management capabilities, proven integrity, honesty, and morality. Candidates with criminal records or pending charges for criminal behavior or those who have faced sanctions related to sports betting are not eligible. Candidates for corporate governance or control positions, whether sports or non-sports, must be able to provide anti-mafia certification as required by the Memorandum of Understanding with the Ministry of the Interior dated May 18, 2016.

14.3 **Prevention of Criminal Influence**: The Club, including its members, administrators, accounting and legality control officers, sports managers, and all employees or collaborators, must ensure that even minimal and non-determinant shares of the capital are not held, directly or indirectly, by entities or individuals associated with organized crime. The Club commits to ensuring that shareholders can continuously provide anti-mafia certification throughout their tenure. Additionally, the Club must prevent proceeds from illegal activities, whether criminal or otherwise, from being invested in any form, including through capital contributions.

14.4 **Ongoing Compliance Requirements**: The absence of final convictions for crimes related to Laws 401/1989 and 376/2000, fraud, and embezzlement, as well as the absence of accessory penalties such as professional or business prohibitions, and the possession of anti-mafia certification requirements, must be maintained by shareholders, corporate officers, and all other sports or non-sports managers for the entire duration of their office and affiliation with the Club. The absence of pending criminal charges for these individuals will be evaluated for ethical and quality certification purposes of Lega Pro's associated clubs.

14.5 **Prohibition on Sports Betting**: The Club, including its members, administrators, accounting and legality control officers, sports managers, and all employees or collaborators, must vigilantly ensure that no member, corporate officer, or staff, whether sports or non-sports, participates in sports betting or prize competitions, even if conducted through legally operating official concessionaires, on events involving Italian teams, including national representatives.

14 bis. 1 **Engagement with Fans and Safety**: The sports club, along with the Supporter Liaison Officer (SLO) and the safety delegate, is committed to maintaining proper communication with fans and collaborating with the safety delegate to address any potential issues related to sporting events.

14 bis. 2 **Fans' Commitment to Club Values**: Fans identify with their team's values, share its history, connection to the community, and values. They commit to embodying these values in the stands, promoting positive behavior, and being a virtuous example of proper fan conduct at all official and friendly sports events. Fans should also promote the club's values on social media and align their behavior with the ethical principles of this Code (the club may specify additional ethical values related to its fan base).

14 bis. 3 **Security Policies and Suspension of Acceptance**: In line with its core values, the club has the authority to implement security policies, as outlined in Article 15, which may include suspending access to events for individuals who exhibit behavior contrary to this Code of Ethics or the regulations governing access to football events.

15.1 **Safety Policies and Measures**: Ravenna Football Club 1913 S.p.A. adheres to safety policies for sporting events as set by CONI, FIFA, UEFA, the relevant League, and general legal regulations. The club is committed to implementing and supporting safety measures at stadiums and sensitive surrounding areas during sporting events. This includes allocating appropriate personnel and resources and strictly following general safety measures provided by the Sports Event Safety Observatory, as well as any additional special measures for high-risk events as determined by the competent authorities.

15.2 **Protocol Compliance and Ticketing**: The club is committed to implementing the August 4, 2017, Memorandum of Understanding between the Ministry of the Interior, Ministry of Sport, CONI, FIGC, Professional Leagues, LND, AIC, AIA, and AIAC concerning the “approval index.” The club will enforce this Code and the Ticket Transfer Regulation Code, applying the "approval" provisions in cases of violation. If a ticket holder violates these provisions, the club has the authority to deny ticket issuance under the August 4, 2017, Protocol.

   In the event of such violations, the club will:

   - Promptly notify ticketing companies of the suspension or revocation of approval for the offending fan.

   - Inform the safety delegate of visiting teams about the suspension or revocation of approval for the fan involved.

15.2 bis **Collaboration with Security Authorities**: The club commits to maintaining ongoing dialogue with relevant security authorities through designated personnel to facilitate information exchange and collaboration before, during, and after matches to prevent disruptions.

15.3 **Conduct and Communication**: The club, along with all its managers, employees, and collaborators, will avoid behaviors and public statements (including through media) that might incite or escalate conflicts incompatible with healthy sports rivalry. This includes preventing potential tensions between spectators and supporters, and mitigating conditions that could lead to violence at or around sports facilities.

16.1 **Compliance with Financial Policies**: The sports club adheres to the financial policies set by FIFA, UEFA, FIGC, and Lega Pro. It adopts and promotes measures to ensure proper and balanced management of its financial assets, maintaining full operational capability throughout its tenure in the relevant competitive levels.

16.2 **Financial Planning and Stability**: The club plans its expenditure and cost sources, both annual and multi-year, according to available resources and investment capacity. It avoids financial transactions or operations that could disrupt its financial balance. To this end, the club conducts thorough technical investigations, including preparing forecast budgets, to ensure that it meets the required economic and financial standards for each league or competition.

17.1 **Compliance with Organizational Policies**: The sports club implements the policies set by FIGC and its relevant league to establish appropriate sports-organizational structures. It ensures that all required roles as defined by current regulatory sources are included in its staff. This includes specialized medical personnel, facility and workplace safety managers, and various sports management positions. The club also strives to minimize the accumulation of multiple roles by the same individuals to ensure the full effectiveness and functionality of each position.

18.1 **Obligation to Report Illicit Conduct**: Ravenna Football Club 1913 Spa, including its members, administrators, financial and legal control bodies, sports managers, and all employees or collaborators, is obligated to immediately report any unlawful acts, actions, or conduct—whether by internal or external parties—to the Federal Prosecutor's Office, relevant judicial police, and the judiciary, depending on their significance. This obligation extends to the reporting of mere attempts at illegal activities, even if not yet completed.

18.1 bis **Reporting of Penalized Fans**: Ravenna Football Club 1913 Spa is committed to notifying the competent authorities about fans who have faced suspension or revocation of "approval" for violations that also have criminal relevance.

18.2 **Individual Reporting Obligation**: The duty to report is required of every individual working for or within the Club, including athletes, coaches, managers (both sports and non-sports), and any other staff or collaborators, regardless of whether the Club has taken action.

18.3 **Prevention and Reporting in Sports Betting**: In the realm of sports betting, even when conducted through legitimate channels and official operators, the Club must adhere strictly to the reporting duty. The Club promotes informational and preventive activities and programs for its members, including athletes, coaches, and managers.

Article 19: Standards of Compliance with the La

19.1 **Professional Conduct and Integrity of Sports Managers**: Sports managers must conduct themselves with the highest level of professionalism and operational capability, adhering to standards of integrity, honesty, and morality. They are required to relinquish their sports positions if they incur criminal penalties. Additionally, they should not face sports-related sanctions connected to involvement in sports betting.

19.2 **Ongoing Requirements for Criminal Records and Anti-Mafia Certification**: The absence of criminal charges and the fulfillment of subjective requirements for anti-mafia certification must be maintained throughout their tenure, whether in a societal or sports role, and for the entire duration of their involvement in Lega Pro's competitive levels.

20.1 **Compliance with Betting Regulations**: Adhering to legal and regulatory standards, including those set by the C.I.O., U.E.F.A., C.O.N.I., F.I.G.C., and Lega Pro, is essential. This includes compliance with the Federale Internal Organizational Norms (N.O.I.F.) and the Sports Justice Code concerning sports betting.

20.2 **Prohibition on Sports Betting**: Sports managers, coaches, athletes, and all other registered individuals are strictly prohibited from participating in sports betting or prize contests related to football events involving Italian teams, including national representatives, directly or indirectly through others.

20.3 **Strict Adherence to Betting Prohibitions**: All sports-related individuals must strictly adhere to the prohibition against betting on sports events, including those outside football, as a preventive measure.

20.4 **Examples of Violations**:

   - Offering or giving money or other benefits for betting purposes to members of the sports organization or third parties.

   - Exercising moral or physical pressure on individuals to influence match outcomes or attempt to fix matches.

   - Participating in associations or contacts with entities involved in sports betting, including any interaction with individuals linked to match-fixing operations.

20.5 **Severe Violations**:

   - Any involvement in the aforementioned activities by senior management or top officials of sports organizations is deemed an absolute violation.

   - Failure to promptly report such violations to the Federal Prosecutor is also considered an absolute violation.

*[1] The Code of Regulation for Access Tickets to Football Events outlines the procedures for revoking or suspending approval based on ethical and behavioral norms that fans must follow both inside the stadium and regarding their team, including on social media. Violations of these regulations may result in suspension or revocation of approval, as per the Protocol with the Ministry of the Interior dated August 4, 2017.*