1. INTRODUCTION

In compliance with the provisions of the Farmindustria Code of Ethics and the Confindustria Medical Devices Code of Ethics, Mastelli S.r.l. publishes, within the first six months of the following year, reports related to transfers of value made during the previous year to:

• Healthcare Professionals (HCPs)
• Healthcare Organizations (HCOs)
• Third Parties (TPs)
  

2. MODALITIES OF PUBLICATION

The data is published:

1. On an individual basis, for transfers of value to Healthcare Professionals who have given their consent, as outlined in Articles 5.5 and 5.7 of the Farmindustria Code of Ethics and Article 4.3 of the Confindustria Medical Devices Code of Ethics.
2. On an aggregate basis, for transfers of value mentioned in point 2 above, if Healthcare Professionals have not consented to individual disclosure.
3. On an individual basis, for transfers of value to Healthcare Organizations and Third Parties, as outlined in Article 5.6 of the Farmindustria Code of Ethics and Article 4.4 of the Confindustria Medical Devices Code of Ethics.
4. On an aggregate basis, for transfers of value mentioned in Article 5.8 of the Farmindustria Code of Ethics and Article 4.5 of the Confindustria Medical Devices Code of Ethics.
   

3. CALCULATION CRITERIA

• Mastelli S.r.l. discloses the number of transfers of value as the net amount, expressed in euros, excluding VAT and gross income taxes charged to the recipient.
• The publication is based on an accrual criterion, meaning that transfers of value corresponding to activities carried out during the reference year are disclosed for that year. The same criterion is also used to prepare the company’s financial statements.
  

4. FINAL NOTES

For matters not addressed in this note, Mastelli refers to the provisions of the Farmindustria Code of Ethics and the Confindustria Medical Devices Code of Ethics, which were followed in drafting this document and are hereby fully incorporated.

Mastelli makes every effort to publish accurate and complete data on transfers of value. Should inaccuracies in the published data occur despite these efforts, Mastelli will make the necessary corrections and additions in a possible adjustment publication in December.