With Legislative Decree No. 231 of 8 June 2001, the legislator introduced at the national level the administrative liability of entities for certain facts constituting offences. This liability is additional to that of the natural person who materially committed the offence and is independent of it.

With this document, the TOTO Group establishes the principles, rights, duties and responsibilities of the company towards shareholders, employees and collaborators, customers, suppliers and public authorities. With it, it also recommends, promotes or prohibits certain conduct from which the company may incur liability or which does not conform to the established ethical principles.

The Code of Ethics (which complies with the principles indicated in the Confindustria Guidelines) constitutes the basis on which the preventive control system is founded, entrusted to a special Supervisory Body with autonomous initiative and control powers, and is an integral part of the Organisation, Management, Control and Anti-Corruption Model adopted by each Company of the Group, containing, amongst other things, the general principles and rules of conduct with which the same Company acknowledges positive ethical value and with which all the addressees of the Code must comply.

This Code of Ethics applies to the entire TOTO Group and therefore, as GUIDELINES, to all the main companies belonging to it and more specifically to TOTO Holding S.p.A. and the underlying companies, whether directly or indirectly controlled or associated, for which it carries out management and coordination activities.

In exercising and maintaining its autonomy, each company may make use of the organisational support of other TOTO Group companies by means of appropriate service contracts, formally established at market prices and in accordance with the procedure system.