Art. No. 1 (2) (pp) of Legislative Decree No. 231/2007 as amended and supplemented

pp) BENEFICIAL OWNER: the natural person(s), other than customer, in which interest, ultimately, the ongoing business relation is established, the professional performance is made or the operation is performed;

Art. No. 20 of Legislative Decree No. 231/2007 as amended and supplemented
Criteria determining beneficial ownership of customers other than natural persons

1. The beneficial owner of customers other than natural persons shall coincide with the natural person(s) to which is attributable, ultimately, the direct or indirect ownership of the company, or its control.

2. In the event the customer is a capital company:
a) it shall constitute an indication of direct ownership the ownership of more than 25% of the capital of the customer, owned by a natural person;
b) it shall constitute an indication of direct ownership the ownership of more than 25% of the capital of the customer, owned through subsidiary companies, trust companies or any other intermediary.

3. In cases where the analysis of the ownership structure does not allow to identify unambiguously the natural person(s) to which is attributable the direct or indirect ownership of the entity, the beneficial owner coincides with the natural person(s) to which is attributable, ultimately, its control by virtue:
a) of the control of the majority of votes in the ordinary shareholder’s meeting;
b) of the control of the votes, sufficient to exercise dominant influence in the ordinary shareholder’s meeting;
c) of the existence of special contractual obligations enabling to exercise dominant influence.

4. In the event the customer is a legal person governed by private law, as per Italian Decree of the President of the Republic dated 10 February 2000, No. 361, are cumulatively identified as beneficial owners:
a) the creators, where alive;
b) the beneficiaries, when identified or easily identifiable;
c) the owners of legal representation powers, management and administration.

5. If the application of the criteria set out in the previous paragraphs does not allow to identify unambiguously one or more beneficial owners, the beneficial owner shall coincide with the natural person(s) which, following the respective organisational or statutory framework, is/are owner(s) of powers of legal representation, administration or management of the company or of the customer anyway other than natural person.

6. Liable parties shall keep record of all checks carried out in order to identify the beneficial owner, as well as, with specific reference to the beneficial owner as identified pursuant to paragraph 5, of the reasons preventing to identify the effective beneficial owner pursuant to paragraphs 1, 2, 3 and 4 of this article.