Handbook of Procedures

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PG ¬SPONS Procedure for sponsorships and donations

1. Purpose of the procedure

2. Definitions

3. Scope of the procedure

4. Operating methods for the management of sponsorships

5. Operating methods for the management of donations

6. Filing

1. Purpose of the procedure

The purpose of this procedure is to regulate the management process for

sponsorships and donations granted by Fondazione Fiera Milano to third parties, in

line with the selected strategic approaches.

2. Definitions

The term (cause-related) sponsorship refers to any payment made to financially

support an event, an activity or an organization in exchange for displaying the

business name / official logo / trademark of Fondazione Fiera Milano through the

media in specific advertising spaces and/or using various communication supports.

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This means that sponsoring does not include individual contributions granted as gifts,

without any contractual undertaking to display Fondazione’s official logo.

By donations reference is made to cash, goods and/or services granted in favor of

specific beneficiaries with a view to supporting projects which are considered worthy

in terms of social, cultural, economic and environmental development and consistent

with the business purpose, values and principles of Fondazione.

3. Scope of the procedure

Sponsorships and donations shall be granted to authorities/associations/foundations

which can prove to be qualified and reliable, after stipulating the relevant agreements

and checking the beneficiary’s good professional standing; no sponsorships or

donations should be granted to counterparts even just suspected of organized crime

connections, or if there is any legal action underway to ascertain their responsibility

pursuant to Lgs. D- 231/01.

When managing this procedure, Fondazione is required to pay specific attention to

possible conflicts of personal or corporate interest, in full compliance with the rules

listed below.

Below is a list of entities which are expressly excluded from sponsoring and donations

by FFM:

authorities and organizations which have not been officially incorporated by

means of a duly registered official document;

parties and political organizations;

trade unions or aid offices;

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entities which directly or indirectly conduct political propaganda activities that

are aimed at influencing the law-making process or electoral campaigns;

entities whose purpose is to limit the freedom and dignity of citizens or to

promote any form of discrimination;

private individuals;

wherever there appears to be a conflict of interest with the work done by FFM

or with members of statutory bodies at FFM.

Any request for sponsorship and donations in favor of public authorities and entities

whose organization or company structure includes persons related to Public

Administration offices needs to be assessed and approved by the Executive

Committee and then promptly notified to the Supervisory Body (SB).

In view of its statutory purposes, priority shall be given by FFM to all those actions

whose objectives can be traced back to promoting cultural, scientific, training,

community and trade fair exchanges within the region of Lombardy, with specific

reference to the Greater Milan area, as well as at domestic and international level. All

of the sponsoring activities carried out have be consistent with Article 1 in

Fondazione’s Articles of Association, for the purpose of enhancing and consolidating

the image and good standing of FFM.

When managing sponsorship activities it will be possible to start specific partnerships

also with other foundations.

Having regard to the management of donations - by means of example and including,

but not limited to - the latter shall be granted in favor of initiatives aimed at economic,

social, cultural and scientific development or requalification of the area, by means of

donations as stipulated according to the subsidiarity principle referred to in Section

1, paragraph 4, of Fondazione’s Articles of Association.

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Generally speaking, the sponsorship and donation initiatives shall never involve

behaviors which clearly suggest any intention to receive or give unfair advantages, or

which create assumptions or factors of illegality or immorality, or which might

jeopardize the integrity or good name of one of the parties and affect the beneficiary’s

independent judgement.

4. Operating methods for the management of sponsorships

The ceiling/plafond for sponsorship proposals needs to be specifically included in the

budget for the Communication and External and Institutional Relations Area (REI), as

part of the objectives set in the relevant three-year Budget Plan and Report for the

fiscal year in question. More specifically, the overall amount of sponsorship

allocations is established by the Executive Committee when drafting the budget,

taking into account the total funds that can be made available by Fondazione Fiera

Milano.

The requests for sponsoring or donations taken into account include the following:

sponsoring as Lead Partner of events and projects with a high cultural, artistic

and social prestige;

sponsoring of organizations that are involved in scientific research, support and

assistance to the community and environmental protection activities.

Any person or corporate Area at Fondazione receiving a request for sponsorship from

a third party is required to notify the Chairman and the General Manager. The general

Management shall then submit any proposals it has received to the in-house board

which is known as Sponsorship and Donations Committee (hereinafter also COSEL).

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COSEL consists of Chairman, General Manager, Governance and Communication Area

Manager, Study and Research Area Manager, Finance and Control Administration

Area Manager (AFC), Legal Area Manager and Technical Area Manager. The proposal

requires a simple majority of participants for approval (regardless of how many are

attending); minutes shall be kept for each COSEL session.

All approved proposals are forwarded to the REI-Communication Area which

evaluates them jointly with the Legal and Corporate Area Manager and the AFC Area

depending on their respective competences.

Before a sponsorship agreement is signed, the REI-Communication Area notifies the

Legal and Corporate Area which runs checks on the potential beneficiary according to

the procedure in the register of suppliers (PA – AF).

The decision regarding sponsorship selections needs to be taken within no more than

60 working calendar days starting from the date on which approval has been given by

COSEL.

In order to be admissible for evaluation, projects need to meet the following

requirements:

all documents certifying the reasons for the sponsorship and their compliance

with the criteria stipulated in the Scope of application for this procedure must

be attached;

the request shall be submitted at least 90 in advance of the starting date

scheduled for the event and/or project;

consistency with the aims pursued by FFM needs to be proved;

generic non-targeted projects shall be specifically excluded;

co-funding by the proposing entity shall cover no less than 70% of the total

estimated expenditure.

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Admissibility of requests in the assessment phase, moreover, needs to be

verified on the basis of the following conditions:

during one calendar year FFM is not allowed to finance the same project more

than once;

during one calendar year FFM is not allowed to finance the same entity more

than once;

no sponsorship may be granted unless the potential beneficiary has submitted a

comprehensive report as to any projects completed using funds previously

provided by FFM.

In addition to the provisions in the paragraph above, if the sponsorship concerns

specific research projects (for example in the area of physics and/or medicine-

science) the financial commitment shall be for no more than three years and co-

funded projects are admissible.

The beneficiary of sponsoring from FFM agrees to mention the financial support

provided by the latter in the relevant official documents.

The REI-Communication Area is expected to contact the sponsored third party to

coordinate all the work necessary to promote the project, as well as to make sure that

FFM is given adequate visibility, in terms of its own logo and of its media exposure.

The REI-Communication Area shall draft and send to the Supervisory Body every six

months, through its Legal Department, a report summarizing the sponsorships

granted by FFM in the course of the fiscal year, detailing the following specific

elements:

• applying entity / beneficiary of the sponsorship;

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• counterpart within the applying entity / beneficiary, specifying any employment

relationship with Public Administration offices;

• nature/type of event being sponsored;

• aims/purpose;

• amount/value paid out in total;

• date of the event;

• date on which the sponsorship is paid;

• entity possibly promoting the initiative;

checking, also on a temporary basis of the correct allocation of funds and

compliance with the agreement by the beneficiary.

The sponsorship fee which is paid to the sponsored entity includes all or part of the

amounts required for the event being sponsored; this will be done only after a specific

agreement to that extent has been signed.

The sponsored entity, once the relevant payment has been cashed, shall issue

invoices or fiscal receipts according to the sponsorship agreement. More specifically,

after the sponsored initiative has been completed, the beneficiary shall send to the

REI-Communication Area at Fondazione, for the appropriate checks, a detailed report

– in writing and fully documented – regarding the correct allocation of everything it

has received, detailing the amounts used and the projects completed.

If the sponsored entity fails to promptly send to the Communication Area the said

documentation, the latter shall immediately report to COSEL and to the SB.

The REI-Communication Area shall:

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file and keep suitable documentation to prove that the sponsorship has been

granted according to the terms approved;

check that the sponsorship corresponds to the agreements undertaken;

request, if possible a feedback report in qualitative and quantitative terms about

the outcome of the sponsorship.

If the REI Communication Area should notice that the sponsorship actually granted

does not correspond to the agreements which were undertaken with the sponsored

entity, it shall immediately report this to COSEL and to the Supervisory Body.

The Administration office pays the invoices in accordance with the Procurement

procedures.

Moreover, no later than the annual deadline and while the budget is being drafted,

COSEL is expected to arrange a meeting to review the work done during the year in

question and make the relevant planning decisions for the following year.

5. Operating methods for the management of donations

FFM shall subsidize selected initiatives organized by third parties based on their

similarity and consistence with the objectives set in the three-year RPP – Budget Plan

and Report in force.

The main operating instruments are:

patronage, paid or free of charge, in support of cultural and training events or

performances;

co-funding of projects or actions with ongoing purposes.

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The person at Fondazione who receives a request for a donation from a third party

shall inform the Chairman and General Manager. The general Management then

submits any proposals received to COSEL:

The proposals received are assessed on a regular basis by COSEL. The ones that are

approved are forwarded to the REI-Communication Area which reviews them in

coordination with the Manager of the Legal Area and of the AFC Area depending on

their respective competences. Before the agreement becomes official, the

Communication Area shall notify the Legal and Corporate Area which checks the

beneficiary for compliance with the register of supplier procedures (PA – AF).

The ceiling/plafond for donations needs to be specifically included in the budget for

Institutional Relations activities, as part of the objectives that are set in the Budget

Plan and Report in force for the fiscal year to which the donation refers. The total

amount of donations requires prior approval by the Executive Committee as part of

the budget, taking into account the overall funds available to Fondazione Fiera

Milano.

The REI-Communication Area, with the support of the FFM bodies in charge, shall

then:

file and keep suitable documentation aimed at proving that the donation has

been made according to the terms agreed;

monitor and benchmark the actions based on the following criteria:

transparency as regards the methods and timing for delivery of the funding

granted; progress reporting on the projects which have been subsidized; review

of the results achieved; compliance with privacy regulations.

The subsidy requests taken into consideration shall include:

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co-funding of highly relevant events and projects from a cultural and social

perspective;

membership of well-established cultural associations, foundations and

authorities with an outstanding reputation;

support to organizations involved in scientific research, help and assistance to

the community and environmental protection.

In order to be admissible for assessment, the projects need to meet the following

requirements:

all documents certifying the reasons for the donation and their compliance with

the criteria stipulated in the Scope of application for this procedure must be

attached;

consistency with the aims pursued by FFM;

the donation may not be used for the purpose of covering previous debts;

generic non-targeted projects shall be specifically excluded;

Admissibility of the applications to the evaluation phase, moreover, needs to be

assessed based on the following conditions:

during one calendar year FFM is not allowed to grant more than one donation

for the same project;

during one calendar year FFM is not allowed to grant more than one donation to

the same entity;

no donation may be granted unless the potential beneficiary has submitted a

comprehensive report as to any projects completed using funds previously

provided by FFM.

The beneficiary of a donation from Fondazione shall mention this in the relevant

official documents. The beneficiary is also required to send to the REI-Communication

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Area at Fondazione, within the next 30 working days, a written report showing that

the funding received has been properly allocated.

In the event that the beneficiary should fail to issue the aforesaid documentation or

that the projects completed should appear not to be compliant with the required

criteria, the REI-Communication Area shall immediately notify the Chairman, the

General Manager, the Sponsorship and Donations Committee and the Supervisory

Body.

Finally, the REI-Communication Area shall file and keep all the documentation aimed

at proving that the donation has been actually granted in accordance with the terms

agreed.

The REI-Communication Area shall draft and send within the annual deadline to the

Supervisory Body a summary report of the donations granted by Fondazione in the

course of the fiscal year, including the following details:

• applying entity / beneficiary of the donation;

• counterpart within the applying entity / beneficiary, specifying any employment

relationship with Public Administration offices;

• nature/type of the event in respect of which the donation is granted;

• aims/purpose;

• amount/value paid out in total;

• date of the event;

• date of the donation;

• entity possibly promoting the initiative.

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6. Filing

All of the relevant documents pertaining to the activities referred to in this procedure

must be kept by the REI-Communication Area for a period of ten years or for any other

length of time which may be stipulated depending on specific regulatory provisions.