The Organization, Management and Control Model (pursuant to Legislative Decree 231/2001) is a comprehensive framework of principles, rules, procedures, and internal controls. Based on a thorough assessment of risks associated with its operations, the Company adopts this Model to prevent the commission of predicate offenses that trigger the criminal-administrative liability of legal entities as defined under Legislative Decree 231/2001.

The 231 Model, which incorporates the Code of Ethics, was officially adopted by LIGHT through a Board of Directors resolution on December 15, 2025. This framework enables the clear identification of individual responsibilities and, by safeguarding the Company as a whole, protects all employees and collaborators who perform their duties in full compliance with corporate regulations and the Law.