Sustainability and ESG Policy

This Sustainability and ESG Policy (Environmental, Social and Governance) is issued by GASPA S.R.L MACCHINE, operating commercially under the brand GASPA MACCHINE, with registered and operational headquarters at Z.I. Predda Niedda Strada 30, 07100 Sassari (SS), Italy, VAT number IT 03006910909, ATECO classification 47.52.40.

GASPA MACCHINE is a dealership specializing in the sale of new and used agricultural and construction machinery, including agricultural tractors, mini-excavators, wheel loaders, excavators, tandem rollers, telescopic handlers, and construction equipment — primarily from leading brands such as JCB. Our business is predominantly focused on the valorization and commercialization of second-hand machinery, actively contributing to a circular economy model that reduces the production of new industrial goods with high environmental impact.

This policy applies to all business activities of GASPA MACCHINE, including online sales conducted through the website gaspa-macchine.com, and covers every product sold and shipped to the following European countries:

The ESG policy of GASPA MACCHINE is not a generic statement of intent: it precisely describes the operational measures, regulatory constraints, and concrete responsibilities that our company commits to respecting in the daily activity of selling, transporting, and providing after-sales assistance for machinery. It is drafted in compliance with current European and national environmental regulations, with the objective of providing maximum transparency to our customers and all stakeholders who interact with our online store.

The core of GASPA MACCHINE's sustainability lies in our business choice to specialize in the buying and selling of used machinery. Every machine we sell is an already-produced asset whose life cycle is extended and whose residual value is preserved and transferred to a new user. This model fits perfectly within the framework of the European Union Circular Economy Action Plan (COM/2020/98), which focuses on waste reduction and extending the useful life of industrial products.

The production of a new agricultural tractor requires on average between 8 and 15 tons of steel, in addition to components made of cast iron, aluminum, copper, rubber, and composite materials. Every used machine we sell avoids the need to produce an equivalent new machine, helping to reduce the consumption of extractive raw materials, the energy consumption of manufacturing plants, and the CO₂ emissions associated with the manufacturing supply chain.

• Extending useful life: we select machinery that is still functionally reliable and make it available to new buyers who extend its use, delaying or avoiding its disposal.
• Transparency on asset condition: each used machine is presented with detailed photographic documentation, indication of working hours and, where available, maintenance history, to ensure an informed evaluation by the buyer.
• Reduction of industrial waste: our business does not generate production waste. Any secondary materials removed during machinery inspection (filters, used oil, batteries) are delivered to authorized collection centers.
• Resource conservation: promoting the purchase of used rather than new machinery reduces the demand for new industrial production, helping to conserve non-renewable natural resources.

GASPA MACCHINE sells two main categories of machinery: agricultural machinery (tractors, agricultural telescopic handlers) and construction and earthmoving machinery (mini-excavators, wheel loaders, excavators, tandem rollers). Each category is subject to a specific regulatory framework regarding emissions, safety, and environmental impact. In the product sheet for each machine for sale on our website, we provide available information regarding the environmental classification of the machine.

Non-road mobile machinery (NRMM), a category that includes all our mini-excavators, loaders, rollers, and handlers, is regulated in terms of emissions by EU Regulation 2016/1628, which entered into force replacing the previous Directive 97/68/EC. Engines produced after the Stage V application dates must comply with much stricter limits in terms of nitrogen oxides (NOₓ), particulate matter (PM), carbon monoxide (CO), and unburned hydrocarbons (HC).

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• Used machinery produced before Stage V Machinery already registered and placed in service before the dates indicated above is not required to comply with Stage V and may be legally sold, transported, and used in the EU as used machinery. GASPA MACCHINE clearly indicates in the technical sheet of each machine the declared or estimated emissions category based on the year of production.

For each machine for sale, where available, we communicate:

• The year of production of the machine and engine.
• The nominal power of the engine in kW.
• The Stage emissions category (if reported in the manufacturer's manual or registration certificate).
• The possible presence of a diesel particulate filter (DPF) or selective catalytic reduction system (SCR/AdBlue).
• Any relevant information on access restrictions in low emission zones (LEZ) known at the time of sale.

Agricultural and construction machinery inherently contains various operating fluids classified as hazardous under Regulation (EC) No. 1272/2008 (CLP) and REACH Regulation (EC) No. 1907/2006. GASPA MACCHINE manages these substances responsibly, in full compliance with Italian and European regulations on the prevention of soil and water pollution.

• Visual inspection of levels and leaks: before each shipment, we inspect machinery to detect active leaks of engine oil, hydraulic oil, or coolant. Machinery with uncontrolled leaks is not shipped until the problem is resolved.
• Fuel management: machinery is shipped with a minimum amount of fuel in the tank (sufficient for loading/unloading operations), in compliance with ADR regulations for road transport of vehicles containing fuel.
• Used oil collection: engine and hydraulic oil removed during pre-sale inspection operations is delivered to the Mandatory Consortium for Used Oils (COOU), pursuant to Legislative Decree 152/2006, Art. 235 et seq.
• No dilution or illegal disposal: GASPA MACCHINE commits not to dispose of oils, liquids, or used fuels in sewers, soil, or surface water. Such behavior is prohibited by Italian law and is subject to criminal penalties under Legislative Decree. 152/2006.

Modern agricultural and construction machinery contains numerous electrical and electronic components (ECU – engine control units, monitoring systems, displays, electrical wiring, sensors, alternators, starter motors). These components fall, at the end of the machine's useful life, into the category of Waste Electrical and Electronic Equipment (WEEE), regulated in Italy by Legislative Decree 49/2014 and at European level by Directive 2012/19/EU.

It is important to clarify a relevant technical-regulatory aspect: complete heavy machinery (tractors, excavators, loaders) does not fall directly within the scope of the WEEE Directive in its entirety, as it is classified as complete industrial machinery. However, the electrical and electronic components that compose them — when removed individually from the machine at end of life — become WEEE and must be disposed of in accordance with applicable regulations.

• Not to dismantle machinery to sell electronic components separately, outside of documented pre-sale inspections.
• To deliver any removed electronic components (defective control units, sensors, displays) to authorized WEEE collection centers pursuant to Legislative Decree. 49/2014.
• Not to dispose of electrical cables, accumulators, or components with printed circuits in ordinary landfills or unauthorized incinerators.
• To provide the buyer with available information on the electronic components present in the purchased machine, so they can properly manage the product's end of life.

Every machine we sell is equipped with at least one lead-acid battery (of the type used for starting the diesel engine), which constitutes one of the components with the greatest potential environmental impact in case of incorrect disposal. Lead-acid batteries contain sulfuric acid and lead, both classified as hazardous substances for the environment and human health.

The reference regulation at European level is EU Regulation 2023/1542 on batteries and waste batteries (which repealed Directive 2006/66/EC from 2023) and, in Italy, Legislative Decree 188/2008 still in force for transition periods.

• GASPA MACCHINE does not sell machinery with lead-acid batteries that show swelling, acid leaks, visible physical damage, or clearly abnormal voltage parameters detected during pre-sale inspection.
• Batteries removed during pre-sale inspection or maintenance operations are delivered to the mandatory collection systems provided by COBAT (National Consortium for the collection and recycling of used lead-acid batteries) in Italy.
• The condition of the battery present on the machine (charge, estimated age if known, any recent replacement) is communicated to the buyer in the sales documentation.

• At the end of the battery's useful life, it must not be abandoned, thrown in unsorted waste, or disposed of in ordinary landfills.
• Used batteries must be delivered to an authorized collection point (battery retailers, affiliated repair shops, municipal collection centers) in the buyer's country.
• In Italy, the legislative decree requires retailers to provide free take-back of the equivalent used battery at the time of purchasing a new battery ("one-for-one" system).

Agricultural and construction machinery, due to their size and weight, are not delivered in conventional packaging. Transport takes place via specialized trucks with lowboy trailers or tow trucks, or on fixed or tilting flatbeds. Despite this particularity, the protection and securing materials used during transport must also be managed responsibly.

• Polyester securing straps: reusable and returned to the carrier after delivery. They do not generate waste at the customer's location.
• Wooden wedges and blocks: used to block wheels and stabilize the machine during transport. Made from chemically untreated wood; disposable as recycled wood in separate collection.
• Plastic protective film: used only to protect components particularly sensitive to moisture or atmospheric agents (displays, connectors, controls). We use the minimum necessary quantity.
• Paper documentation: we use only recycled paper for transport documents, technical sheets, and instructions included with delivery.

The new EU Directive 2024/1136 on packaging and packaging waste (which updates and replaces Directive 94/62/EC) introduces more ambitious objectives for reduction, reuse, and recyclability of packaging. Although heavy machinery is not subject to the same rules as retail packaging, GASPA MACCHINE voluntarily applies the principles of this regulation:

• Minimization of packaging material used.
• Preference for 100% reusable or recyclable materials.
• Elimination of unnecessary single-use plastics in packaging materials associated with delivery.

The transport of heavy machinery over long European distances is one of the activities with the greatest environmental impact in our value chain. GASPA MACCHINE is aware of this reality and adopts a responsible approach in selecting carriers and optimizing shipments, while recognizing that, in the heavy machinery sector, transport by specialized truck is often the only technically feasible method.

• Transport by lowboy truck (lowloader): primary method for international deliveries to all European countries.
• Tow truck or tilting trailer: used for smaller machinery (mini-excavators, light rollers) or for short distances within Italy.
• Combined rail transport: evaluated as an option in cases where it is technically and economically feasible for northern European destinations (Finland, northern Germany, Netherlands).

• Load optimization: when possible, we consolidate multiple machines destined for nearby geographical areas in a single transport, reducing the total number of trips.
• Selection of carriers with Euro VI fleet: we favor transporters with vehicles compliant with the Euro VI emissions standard, the most recent for heavy vehicles in the EU (Regulation EC 595/2009).
• Optimized routes: our logistics partners plan routes avoiding unnecessarily long journeys, reducing empty kilometers, and optimizing loading and unloading times.
• No air transport: due to the nature and weight of the machinery sold, air transport is never used. Road transport is widely preferred over air transport in terms of emissions per tonne-km transported.

Agricultural and construction machinery, at the end of its useful life, constitutes a complex industrial waste stream, governed by specific regulations. In Italy, the main regulatory framework of reference is Legislative Decree 152/2006 (Consolidated Environmental Act), Part Four, which implements the Waste Framework Directive 2008/98/EC, replaced by Directive 2018/851/EU. At a specific level for end-of-life vehicles, Directive 2000/53/EC (ELV – End of Life Vehicles) applies, implemented in Italy by Legislative Decree 209/2003.

It is necessary to specify that the ELV Directive (End of Life Vehicles) 2000/53/EC applies to motor vehicles in categories M1 and N1 (passenger cars and light commercial vehicles), not to agricultural or construction machinery. However, many European countries apply similar or broader regulations that extend the principles of responsible end-of-life management to heavy machinery and agricultural equipment as well.

• Authorized collection and dismantling centers: in every country where we operate, there are authorized treatment facilities for the dismantling of vehicles and heavy machinery. Machinery must be delivered to these centers, which will handle the draining of fluids, separation of ferrous materials, collection of hazardous components, and recycling of recoverable materials.
• Steel recovery: over 90% of the weight of a typical excavator or tractor consists of steel, cast iron, and aluminum, all highly recyclable. Authorized dismantling centers handle their separation and delivery to recycling facilities.
• Separate disposal of fluids: before physical dismantling, all fluids (engine oil, hydraulic oil, fuel, coolant, AdBlue) must be drained and delivered separately to hazardous substance collection centers.
• End-of-life tires (ELT): tires from tractors, excavators, and rollers fall under the ELT category, regulated in Italy by Ministerial Decree 82/2011. Their disposal is free of charge for the consumer at tire dealers (one-to-one system) or collection centers affiliated with Ecopneus or Greentyre.

Agricultural and construction machinery contains materials that may include substances subject to REACH Regulation (EC) No. 1907/2006 (Registration, Evaluation, Authorisation and Restriction of Chemicals) and, for electronic components, to the restrictions of the RoHS Directive (2011/65/EU) on hazardous substances in electrical and electronic equipment.

• Lead in starter batteries (see Section 7).
• Polycyclic aromatic hydrocarbons (PAHs) in gaskets or rubber hoses of older generation.
• Mineral oils and hydraulic fluids (see Section 5).
• Asbestos: completely absent in machinery produced after 1995. Machinery produced before that date may contain asbestos gaskets; GASPA MACCHINE does not sell machinery with asbestos components identified as such. In case of uncertainty about the year or the presence of asbestos in very old machinery, the purchaser must have the components verified by a qualified technician before any maintenance or disassembly work.
• Hexavalent chromium: present in some older generation industrial paints. Machinery is sold without disassembly or sanding of painted surfaces.

For every chemical substance we use in pre-sale verification operations (e.g., cleaning products, lubricants), GASPA MACCHINE has the relevant Safety Data Sheets (SDS), in accordance with Article 31 of the REACH Regulation. SDS are available upon written request at info@gaspa-macchine.com.

The RoHS Directive 2011/65/EU applies to electrical and electronic equipment (EEE) as such, not to heavy machinery in its entirety. However, spare electronic components that are purchased separately and installed on machinery (control units, displays, control modules) must comply with RoHS if produced after the applicable dates. GASPA MACCHINE does not sell separate electronic components; however, for machinery equipped with aftermarket replacement electronic components, we invite purchasers to verify the RoHS compliance of the installed component.

The social dimension (S) of GASPA MACCHINE's ESG framework concerns how our company relates to people: our customers throughout Europe, the workers operating within our business, and the local community in which we are rooted in Sassari. We adopt an approach based on respect, transparency, and the effective protection of the rights of every person we interact with.

• Complete and truthful information: every machine published on our site is described with available information in an accurate and up-to-date manner: year of production, working hours, general condition, any known defects, emission category, and photographic documentation. We do not use misleading or omissive descriptions.
• 14-day right of withdrawal: private consumers purchasing through our site have the right to withdraw within 14 calendar days of delivery, pursuant to Legislative Decree 21/2014 and EU Directive 2011/83 on consumer rights. The refund is processed within 14 working days of receiving the returned machine in a condition consistent with what was declared at the time of purchase.
• Accessibility of information: all our policies (returns, shipping, warranty, sustainability, payment methods) are publicly accessible on the gaspa-macchine.com website, without the need for registration or login. The texts are written in Italian and are clear, specific, and free of excessive technical language.
• Payment security: GASPA MACCHINE exclusively uses secure and certified payment systems. We do not collect or store customer credit card data on our servers. All transactions are managed through payment gateways compliant with the PCI-DSS standard.
• Privacy and personal data protection: customers' personal data are processed in accordance with EU Regulation 2016/679 (GDPR) and Legislative Decree 196/2003 (Privacy Code) as amended by Legislative Decree. 101/2018. Data is not sold to third parties. Our privacy policy is available at gaspa-macchine.com/privacy-policy/.
• Non-discrimination: GASPA MACCHINE sells to all European customers without discrimination based on nationality, country of residence (within the limits of the countries where we operate), age (for adult buyers), gender, or other personal characteristics. We do not apply differentiated prices or conditions based on the customer's nationality, in accordance with EU Regulation 2018/302 (Geo-blocking).

GASPA S.R.L MACCHINE operates in compliance with all Italian labor laws and applicable European regulations. In particular:

• All employees and collaborators are hired or engaged with regular contracts, in full compliance with the Italian Civil Code, Legislative Decree 81/2008 (occupational safety), and the national collective labor agreements applicable to the trade sector.
• Workplaces comply with the safety standards provided by Legislative Decree 81/2008, with particular attention to operations involving the handling of heavy loads, the use of lifting equipment, and access to areas with machinery in operation.
• We do not use child labor or forced or unpaid labor. Respect for the Fundamental Principles of the ILO (International Labour Organization) is non-negotiable in every aspect of our business.

GASPA MACCHINE is a company rooted in the territory of Sassari and northern Sardinia. We contribute to the local economy through direct employment, the use of local suppliers and logistics partners when available, and compliance with Italian tax and social security obligations. We do not have offshore structures or aggressive tax planning mechanisms.

The Governance (G) dimension of the ESG framework concerns how GASPA MACCHINE makes decisions, manages risks, complies with laws, and maintains its commercial integrity. Solid governance is the foundation that ensures the long-term credibility and sustainability of our business.

• Compliance with the Italian Consumer Code (Legislative Decree 206/2005): our commercial policies fully comply with Italian legislation and European directives applicable to distance selling to consumers.
• Compliance with Legislative Decree 70/2003 (electronic commerce): mandatory information regarding our identity, registered office, VAT number, and contact details is publicly accessible on the site at all times.
• Compliance with EU Regulation 2022/2065 (DSA – Digital Services Act): GASPA MACCHINE complies with the obligations provided by the Digital Services Act for small platforms, including the removal of illegal content and cooperation with competent authorities.
• Tax compliance: GASPA S.R.L MACCHINE is regularly registered in the Business Register of the Chamber of Commerce of Sassari, fulfills the tax obligations provided by Italian legislation (VAT, IRES, IRAP), and correctly applies the rules on intra-community VAT for sales to EU countries, pursuant to EU Directive 2006/112/EC as amended by Directive 2017/2455 (OSS/MOSS).

• GASPA MACCHINE does not accept or offer informal payments, illegal commissions, gifts of significant value, or any other form of commercial corruption in relations with suppliers, carriers, buyers, or public authorities.
• We do not use unfair commercial practices pursuant to Arts. 20-27 of the Consumer Code (Legislative Decree 206/2005) and EU Directive 2005/29/EC on unfair commercial practices.
• We do not use misleading advertising or illegal comparative advertising. The descriptions of the products published on our site are truthful and verifiable.

A crucial aspect of our governance is the verification of the lawful origin of every machine we purchase for resale. In particular:

• We verify that each machine is the legitimate property of the seller, through the check of ownership documents, registration certificates, or declarations of conformity.
• We check that the chassis numbers (VIN) have not been altered or erased, which would constitute a clear sign of illegal origin.
• We do not purchase machines of doubtful origin or lacking sufficient documentation to guarantee the legality of the transfer of ownership.
• We keep the documentation relating to every machine purchased and resold for the minimum period required by Italian tax legislation (10 years).

GASPA MACCHINE is committed to monitoring and improving its ESG performance over time. Even in the absence of the non-financial reporting obligation (provided by the CSRD Directive – Corporate Sustainability Reporting Directive 2022/2464/EU only for large enterprises), we update this policy at least once a year and whenever significant regulatory changes or changes in our operational activity occur.

Every country to which GASPA MACCHINE delivers machinery has its own national environmental regulatory framework, which overlaps and integrates the reference European legislation. Below we provide an overview of the main country-specific environmental obligations and constraints relevant to buyers of agricultural and construction machinery.

The Italian environmental regulatory framework is mainly contained in Legislative Decree 152/2006 (Environmental Consolidation Act – TUA). For agricultural machinery, Legislative Decree 228/2001 and regional ARPA (Regional Agencies for Environmental Protection) regulations for operational authorizations in protected areas also apply. The use of earthmoving machinery in urban areas is subject to any municipal ordinances on noise emissions (Legislative Decree 194/2005 – noise directive). ELTs (end-of-life tires) are governed by Ministerial Decree 82/2011.

In Austria, the main environmental legislation for heavy machinery is governed by the Umweltschutzgesetz and specific directives from the Bundesministerium für Klimaschutz (BMK). The use of construction machinery in protected zones or urban areas is subject to permits from local authorities (Bezirkshauptmannschaft). Waste management is regulated by the Abfallwirtschaftsgesetz (AWG 2002). Hazardous fluids must be disposed of through Altstoff Recycling Austria AG (ARA).

In Finland, the environmental legislation applicable to machinery is contained in the Environmental Protection Act (Ympäristönsuojelulaki 527/2014) and the Waste Act (Jätelaki 646/2011). The use of agricultural and construction machinery is subject to environmental permits from regional authorities (ELY Centres). Finland applies some of the strictest EU standards regarding the protection of water bodies from mechanical fluid discharges.

In France, agricultural and construction machinery are governed by the Code de l'environnement and regulations from ADEME (Agence de la transition écologique). In areas classified as Zones à Faibles Émissions (ZFE) in metropolitan areas (Paris, Lyon, Marseille, etc.), machines with older generation engines may be subject to access restrictions. The management of waste oils is governed by the filière de collecte des huiles usagées system.

Germany applies some of the strictest environmental standards in the EU. The Bundes-Immissionsschutzgesetz (BImSchG) regulates atmospheric pollutant emissions, while the Kreislaufwirtschaftsgesetz (KrWG) governs waste management. Machines operating in many German cities must comply with Umweltzonen (environmental zones), although these mainly apply to road vehicles. Noise emission standards for construction sites are particularly restrictive in residential areas, pursuant to the Geräteschutzlärmgesetz (GSG).

In the Netherlands, the environmental legislation applicable to machinery is contained in the Activiteitenbesluit milieubeheer and the Wet milieubeheer. The Netherlands has one of the most efficient waste management systems in Europe. Construction machinery in sensitive urban areas must comply with the noise emission standards of the Municipalities' Environmental Zones. Waste oil management takes place through the VROM Circulair system.

In Poland, the main environmental legislation is the Ustawa Prawo Ochrony Środowiska (POŚ) and the Ustawa o odpadach (Waste Act) of 2012. Hazardous waste management is regulated by the Inspekcja Ochrony Środowiska (GIOŚ). Waste fluids must be disposed of through authorized collectors. Poland is progressively introducing stricter emission regulations for urban construction sites.

In Romania, environmental legislation is governed by Legea Mediului nr. 265/2006 and the implementing decrees of the Agenția Națională pentru Protecția Mediului (ANPM). Romania has transposed all major European environmental directives, including those on NRMM emissions, waste management, and water protection. Compliance with standards may vary in territorial application; the buyer is recommended to verify specific local requirements.

In Spain, the environmental framework is governed by Ley 7/2022 de residuos y suelos contaminados para una economía circular (which replaced Ley 22/2011) and Ley 34/2007 de calidad del aire y protección de la atmósfera. Large Spanish cities (Madrid, Barcelona, Valencia) have introduced Zonas de Bajas Emisiones (ZBE) with restrictions for vehicles and, in some cases, for construction machinery with older generation engines.

Switzerland is not a member of the EU but has its own environmental regulations, often stricter than European ones. The main legislation is the Luftreinhalte-Verordnung (LRV) for atmospheric emissions and the Umweltschutzgesetz (USG) for general environmental protection. Switzerland applied NRMM emission limits similar to Stage V even before the European obligation. Hazardous waste management is regulated by the VEVA (Verordnung über den Verkehr mit Abfällen). The import of machines from EU countries is subject to any customs duties and checks by the FOEN (Federal Office for the Environment).

Once the machine has been delivered and the risk is transferred to the buyer, the latter becomes responsible for the environmental management of the machine and all materials that compose it or that it uses. GASPA MACCHINE provides below a summary of the main obligations incumbent on the buyer in accordance with the legislation of the country of destination.

• Fluid management: maintain, replace, and dispose of engine oil, hydraulic oil, coolant, and fuel in accordance with local regulations. Do not discharge fluids into the soil or surface waters.
• Filter disposal: waste oil and air filters are hazardous waste and must be disposed of through authorized channels in the buyer's country.
• Emission system maintenance: do not remove, tamper with, or disable the emission control systems installed on the machine (DPF, SCR, EGR). Such behavior is illegal in all EU countries and Switzerland and can lead to significant penalties.
• Verification of local permits: verify that the machine is authorized for use in the geographical area and in the type of construction site or terrain where it will be employed, with particular attention to urban Low Emission Zones.
• End-of-life tires: dispose of worn tires through authorized ELT collection systems in the buyer's country.
• Waste batteries: deliver waste starter batteries to authorized collection points (see Section 7).
• End of life of the machine: at the end of its useful life, deliver the machine to an authorized demolition center and do not abandon or dispose of it illegally (see Section 10).
• Operational safety: use the machine in accordance with the manufacturer's instructions and the occupational safety regulations applicable in the buyer's country (in Italy: Legislative Decree 81/2008).

This Sustainability and ESG Policy is a living document, subject to periodic review and update in response to regulatory changes, evolutions in GASPA MACCHINE's operational practices, and improvements in the understanding and management of ESG risks in the used machinery trade sector.

• Annual ordinary review: at least once a year, by December 31 of each calendar year, we verify that the contents of the policy are aligned with the regulations in force in all countries where we operate.
• Extraordinary review: in case of significant regulatory changes (e.g., new European directives, changes to Stage V requirements, new ZFE/LEZ restrictions), we update the policy within 60 days of the new regulation coming into force.
• Operational review: in case of relevant variations in the type of products sold, in shipping methods, or in destination countries, the policy is updated before starting the new activities.

In case of substantial changes to this policy, we inform our customers via:

• A visible notice on the homepage of the gaspa-macchine.com website for a period of at least 30 days from the update date.
• Updating the "Last updated" date reported at the top of this page.
• Direct communication via email to customers who have made purchases in the previous 12 months, in case of changes that significantly affect their rights or obligations.