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Business Overview and Performance      Corporate Governance     Financial Statements   Enclosure



         In addition, the Parliament of Italy is now reviewing    food/beverage businesses must undergo training
         a draft law that may require shops and department    related to their operations, food/beverage preparations
         stores to close on Sunday and national holidays.     and management. Also, the operators must complete
         At present, it remains unclear as to whether the draft law     secondary education or higher education in the field
         will receive parliamentary approval and whether      of trade and food preparations. In addition, they must
         the  said  draft  law  will  grant  certain  exemptions.     have  operated  food  services/food  and  beverage
         There are also uncertainties about how local authorities   services  for  a  combined  period  of  at  least  two  years
         will enforce this law, if it is introduced.          during the past five years prior to applying for a license
                                                              (Article 71, Clause 5 of Legislative Decree 59/2010).
         2. Law on Food and Beverage Services
                                                              3. Laws on Jewelry Trade
         In Italy, services related to food and beverages
         including alcoholic drinks for members of the public or     Regarding  stipulations  on jewelry retail,  Article 127
         in a public space are under Law No. 287/1991         of Consolidated Act of Public Security (pursuant to
         that is issued pursuant to Legislative Decree 59/2010   Royal Decree No. 773 dated 18 June 1931 or “ICAPS”)
         as well as regional/local laws/rules (including those of   requires manufacturers, traders or agents of gems
         municipalities). Such services refer to the distribution of   or  precious  items  to  seek  and  obtain  a  license  from
         food and beverages to customers for consumption within   the chief of police departments in their areas (enforcing
         the places of business (such as bars or restaurants) or     local officials). This license applies to all kinds of shops
         a public space or an area designated for food/beverage   or retail outlets of the same company, regardless of
         services (Article 1 of Law No. 287/1991).            where they are located (Article 127.4 of ICAPS).
                                                              These legal stipulations apply to foreign traders,
         Generally, to start or transfer a food/beverage business   manufacturers  and  entrepreneurs  engaged  in
         requires the submission of a letter on the start of   the distribution of precious metals in Italy.
         operations or SCIA (segnalazione certificate di inizio
         attività). With the submission, the business can be   Agents, representatives, and salespersons of the foreign
         immediately launched while officials reserve the right   entrepreneurs have the duty to seek the license by
         to review documents or compliance with applicable    proving their status based on certificates issued by
         regulations for 60 days since the submission (Article 54,     authorities of countries where their companies have been
         Clause 1 of Legislative Decree 59/2010).             registered. The certificates must be certified by an Italian
                                                              consulate  too  (Articles  127.5  and  5.6  of  ICAPS).
         For a business unit located inside a protected area   Article 243 of rule on ICAPS compliance, which is
         (such as old town, historical town, or art town),     pursuant to Royal Decree No. 635 dated 6 May 1940,
         the start or transfer of food/beverage business is subject     stipulates that manufacturers, traders, and agents of
         to provisions on official license applications and    precious metals have the duty to seek a license from
         certain restrictions such as the maximum number of     police chiefs even when they conduct their operations on
         new businesses allowed (Article 54, Clause 3 of      an occasional basis. The issuance of licenses shall be
         Legislative Decree 59/2010).                         subject  to  some  ethical  requirements  as  stated  in
                                                              Article 11 of ICAPS (for example, license holders must
         Starting a business requires compliance with regulations    not be a convict of serious crimes against others, theft,
         on town planning, laws on building controls, hygiene,   robbery, extortion, kidnapping or a crime against the
         and workplace safety (Article 54 Clause 6 of Legislative   state or public order).
         Decree 59/2010), as well as any technical standards
         issued by local authorities. Regarding a food/beverage
         business, Article 71 of Legislative Decree 59/2010
         stipulates  that business operators must comply with
         good reputation stipulations (as mentioned earlier for
         retail businesses) as well as requirements related to
         their professions. For example, the operators of



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