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ITEM 16B. CODE OF ETHICS

We have adopted a Code of Ethics that applies to all of our employees, officers and Directors, including those officers responsible for financial reporting. Our Code of Ethics is available on our website (https://www.zegnagroup.com). We intend to disclose any amendment to our Code of Ethics, or any waivers of its requirements, in our annual report on Form 20-F. For the year ended December 31, 2025, we did not grant any waivers of the Code of Ethics.

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