WHISTLEBLOWING

REPORTING UNLAWFUL CONDUCT

Whistleblowing is a tool that allows you to report, safely and anonymously, unlawful conduct or irregularities within our organization that you are aware of or that directly involve you. The platform guarantees confidentiality and protection, helping you contribute to a more ethical and transparent environment.

How does it work?

1. Access the Our Whistleblowing platform by clicking the button at the bottom of the page;

2. Choose whether to report anonymously or register;

3. Fill out the form describing the issue;

4. Submit the report.

• If anonymous: You will receive a unique code that you must store, as it will not be retrievable in any way. This code will allow you to monitor the status of your report by logging back into the platform.
• If registered: You will receive updates directly without having to log in manually.

Your identity is always protected

Italian law (Legislative Decree 24/2023, implementing EU Directive 2019/1937) establishes that the whistleblower's identity must remain confidential, even if you decide to register and provide a contact method.

Identity disclosure is only permitted in exceptional circumstances, such as:

✔ Judicial or administrative investigations requiring it.

✔ Your explicit consent.

No unauthorized person will ever have access to your data, and strong protections against retaliation or pressure are in place.

Who can contact you?

Only independent and separate entities from the organization responsible for managing reports in an impartial and secure manner:

✔ Whistleblowing report manager (e.g., supervisory body, compliance officer, whistleblowing manager) for any clarifications or additional information.

✔ Judicial or administrative authorities if the report leads to an official investigation.

✔ Authorized third parties, such as external investigators, but only if strictly necessary and always respecting your anonymity.

Who CANNOT contact you?

❌ No internal organization members involved in the reported events can access your identity or contact you.

❌ No retaliatory actions can be taken against you (dismissal, demotion, threats).

Better anonymous or registered?

• Anonymous Reporter: You will receive a unique code that you must store, as it will no longer be available in any way. This code will allow you to access the platform again to check the status of your report. However, you will not receive notifications or alerts, so you will need to check updates on your own initiative.
• Registered Reporter (Recommended): Your identity remains anonymous and protected, but by registering, you can:

  ✔ Receive updates directly without needing to log in manually.

  ✔ Be contacted only by independent and authorized personnel to enhance the effectiveness of the report management.

  ✔ Facilitate contact from competent authorities if necessary, always ensuring your confidentiality.

  ✔ Have a greater chance of contributing to a timely resolution.

👉 Registering facilitates more effective report management. The system ensures secure and protected communication with responsible parties, allowing you to actively contribute to resolving the issue while ensuring your complete protection.