LEGAL REFERENCES

• Italian Legislative Decree 24/2023, “Implementation of EU Directive 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law and establishing provisions on the protection of persons who report breaches of national law”;
• EU Directive 2019/193 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law and establishing provisions regarding the protection of persons who report breaches of national law;
• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27/04/2016: General Data Protection Regulation;
• Italian Legislative Decree 196 of 30 June 2003, containing the Data Protection Code.

RECIPIENTS AND DISTRIBUTION

Any person (the ‘Whistleblower’) who has a working relationship with the Company, regardless of their legal or contractual status, may make a report including after the employment relationship has ended, that is to say:

• employees or self-employed workers;
• Employees with non-standard contracts, such as part-time and fixed-term contracts, including those who have a contract or employment relationship with a temporary work agency;
• applicants;
• trainees;
• Ex employees;
• volunteers and trainees, including unpaid;
• shareholders and persons holding positions of administration, management, control, supervision or representation, including de facto;
• freelancers and consultants;
• sub-contractors;
• suppliers.

Reports can be submitted at any time via the digital whistleblowing portal. For verbal reports made by telephone, please refer to the times specified in section 5.3 A of this policy.
The procedure can be accessed:

• In electronic format on the Company’s website (Whistleblowing – Focaccia Group);
• In hard copy on the company noticeboards
• The same methods of distribution outlined above shall apply to any subsequent revisions and amendments to the Policy.

Purpose of the Report

The Whistleblower MAY SUBMIT DETAILED REPORTS CONCERNING:

• Alleged breaches, incitement or inducement to breach laws or regulations, internal procedures, or the Company’s Code of Ethics;
• Offences falling within the scope of EU or national legislation (public procurement; services, products and financial markets; and the prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and fodder safety; and animal health and welfare; public health; consumer protection; protection of privacy and personal data, and security of network and information systems);
• Acts or omissions relating to the internal market, pursuant to art. 26, sub. 2 TFEU, including breaches of EU competition and State aid laws, as well as breaches of corporate tax laws;
• Acts and omissions that undermine the financial interests of the Union, as protected under art. 325 TFEU;
• Acts or conduct that undermine the purpose or objective of the provisions envisaged by the EU documents referred to in the above points

The following reports are not taken into account and are NOT PERMITTED:

• Reports inherent to alleged breaches, acts or omissions which the Whistleblower has no reasonable grounds to believe are true;
• Reports that appear to be groundless, defamatory or slanderous, and lack objective evidence
• Reports that are discriminatory in nature, as they refer to the sexual orientation, religious or political beliefs, or racial or ethnic origin of the person Reported;
• Reports that are solely intended to harm the person Reported;
• Reports that constitute forms of abuse and/or misuse of this Procedure and the Whistleblowing mechanism;
• Reports that concern matters relating to national security and defence;
• Reports that contain complaints or personal grievances on the part of the Whistleblower;
• Reports that relate to aspects of the reported person’s private life, with no direct or indirect connection to their corporate and/or professional activities;
• Reports that include complaints, claims or communications relating to the individual’s personal interests and concerning their individual working relationships with their superiors (e.g. employment disputes, discrimination between colleagues, interpersonal conflicts in the workplace, etc.).

Please do not use this channel for complaints, messages or suggestions.

Whistleblowing channels

External Channel

applicable only in the following cases:

• The Whistleblower has already submitted an internal report, but no action was taken on the same;
• The Whistleblower has reasonable grounds to believe that, if they were to make an internal report, it would not be dealt with effectively, or that making such a report could lead to a risk of retaliation;
• The Whistleblower has reasonable grounds to believe that the breach may constitute an imminent or clear danger to the public interest.

Whistleblowing Channel

Each report will be assigned a tracking code, which can be used to monitor the progress of the process, in compliance with the law.

Whistleblowing Channel

Verbal Channel

It is possible to use the telephone channel. This channel can be used to submit reports or request
a direct appointment with the manager. All verbal reports will be recorded and logged on the
management platform, and each will be assigned a specific reference number, which will be
provided to the whistleblower so that they can monitor the progress of the same. In such cases,
the Company will guarantee that the meeting takes place within 10 (ten) business days.

The following individuals can be contacted in their capacity as Anti-Corruption and Transparency Officers

Chiara Biagini (Preference) 0544 202330
Rocco Scocozza 0544 202323

Public Disclosure

Art. 15 of Italian Legislative Decree 24/2023 introduces a further whistleblowing option referred to as the so-called Public Disclosure.
Through public disclosure, information regarding breaches is made public via the press or electronic media, or through other means of dissemination capable of reaching a large number of people.
However, in order to benefit from the protections envisaged by Italian Legislative Decree 24/2023: Public disclosure of breaches must take place where one of the following conditions applies:

• The whistleblower has previously made an internal and external report, or has made an external report directly, without receiving a response within the specified deadline regarding the measures planned or taken to follow up on the reports;
• The Whistleblower has reasonable grounds to believe that the breach may constitute an imminent or clear danger to the public interest;
• The whistleblower has reasonable grounds to believe that reporting the matter externally may expose them to the risk of retaliation or may not be effectively followed up due to the specific circumstances of the case in question, such as where evidence may be concealed or destroyed, or where there is a well-founded fear that the person receiving the report may be colluding with the perpetrator of the breach or involved in the breach itself.