TRANSACTIONS WITH RELATED — PARTIES PROCEDURE

The Procedure for Related-Parties Transactions establishes the provisions aimed at ensuring the transparency and substantive and procedural correctness of Related-Parties Transactions carried out by Pirelli, directly or through its subsidiaries, that are of Greater Importance - namely, Transactions that exceed the thresholds set out in Annex 3 of the Consob Regulation no. 17221/2010 as subsequently amended (“RPT Regulation”) or that, while not exceeding these thresholds, by their nature, strategic importance, entities or commitments have a significant impact on the activity of the Company or the Group, or may affect the autonomy management of the Company (so called Transactions of Strategic Importance) – or, of Lesser Importance (i.e. Transactions with Related-Parties different from the Greater Importance Transactions and the Smaller Amount Transactions).

According to RPT Regulation the Board of Directors in the meeting held on 9 May 2024, following the unanimous favorable opinion expressed by the Related-Parties Transactions Committee, approved the Procedure for Related-Parties Transactions.

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Procedure for Related-Parties Transactions approved on 9 May 2024

Last revised: 9 May 2024