WHISTLEBLOWING

WHISTLEBLOWING POLICY

CONTENTS 1. PURPOSE AND SCOPE 2. REGULATORY REFERENCES 2.1 ANNEXES 3. TERMS AND DEFINITIONS 4. ROLES IN THE INVESTIGATION PROCESS 5. OPERATING PROCEDURES 5.1 GUIDING PRINCIPLES 5.2 WHISTLEBLOWING REPORTS 5.3 PRIVACY 6. DOCUMENT TRACEABILITY AND RETENTION

1. PURPOSE AND SCOPE

1.1 Purpose of this document

In pursuing its business objectives, Successori Reda S.B.p.A. is committed to combating unlawful conduct and, in particular, corruption at every level of the organisation. It does so both by disseminating and promoting ethical values and principles and by effectively implementing rules of conduct and control processes, in line with applicable regulatory requirements and recognised best practices.

Successori Reda has developed corporate protocols and controls to eliminate or minimise the risk of offences being committed in activities that are potentially more exposed to unlawful conduct.

To further implement its reference documents and the highest applicable standards, this policy defines and describes the process for handling reports, including anonymous reports, submitted by anyone who becomes aware of acts or circumstances that are, even potentially, contrary to the law or the company’s internal rules.

1.2 Intended recipients and scope

This policy applies to:

• Successori Reda employees and job applicants;

• External collaborators;

• Group companies;

• Partner companies;

• Customers;

• Suppliers;

• Anyone in contact with Successori Reda S.p.A. in the course of their professional activities.

2. REGULATORY REFERENCES

Codice	Titolo
Legislative Decree 24/2023 Law 179/17	Legislative Decree No. 24 of 10 March 2023. Law No. 179 of 30 November 2017.
Legge 127/22	Legge 4 agosto 2022, n. 127
Direttiva (UE) 2019/1937	Direttiva (UE) 2019/1937 del Parlamento Europeo e del Consiglio del 23 ottobre 2019
D.Lgs. 231/01	Decreto Legislativo 8 giugno 2001, n. 231
Modello 231	Modello di Organizzazione, Gestione e Controllo adottato dall’azienda ai sensi del D. Lgs. 231/01

3. TERMS AND DEFINITIONS

Termine	Definizione
Whistleblowing	Denuncia/segnalazione posta in essere dal whistleblower.
Segnalante o Whistleblower	Soggetto, interno o esterno all’azienda, che denuncia, alle autorità o agli organi aziendali preposti, attività illecite o fraudolente poste in essere dall’organizzazione. Le rivelazioni possono essere di varia natura: violazione di una legge, di un regolamento, di una policy, di un codice etico comportamentale.
Segnalato	Soggetto, interno o esterno all’azienda, che secondo la segnalazione del whistleblower ha tenuto o tentato comportamenti illeciti e/o omissivi, contrari alle norme applicabili e ai regolamenti interni.
Modello di Organizzazione, Gestione e Controllo (Modello 231)	l modello di organizzazione e gestione (o “modello ex d.lgs. n. 231/2001), ai sensi della legge italiana, indica un modello organizzativo adottato da persona giuridica, o associazione priva di personalità giuridica, volto a prevenire la responsabilità penale degli enti. È normalmente formato da una Parte Generale e una Parte Speciale elaborata caso per caso a seguito della mappatura delle attività a rischio reato.
Ricevente	Soggetto interno che riceve la segnalazione e la elabora nel rispetto delle indicazioni e cautele definiti dal presente documento
OdV delegato	Organismo di Vigilanza formalmente incaricato per la gestione del canale di segnalazioni whistleblowing.
CdA	Consiglio di Amministrazione

4. ROLES IN THE INVESTIGATION PROCESS

Reporting person: a person who becomes aware of unlawful conduct and/or conduct contrary to internal rules and submits a report through the confidential channel provided by the company. Their identity is confidential and known only to the Supervisory Body managing the whistleblowing channel.

Recipient: the Supervisory Body, which receives and analyses the report, taking care to omit any data that might identify the reporting person, even indirectly.

Supervisory Body: upon receiving a report, it begins the investigation stage to analyse its content and assess its relevance and substance, requesting further details from the reporting person where necessary. For verification purposes, the Body may commission specialist internal departments and/or third parties to carry out further inquiries, always respecting the confidentiality of both the reporting person and the reported person.

Chair of the Supervisory Body: after the investigation stage, if the report is substantiated and relevant, the Chair provides appropriate information to the Chair of the Board of Directors concerning the reported facts, the breaches of Model 231 identified during the investigation and the responsibilities established.

Board of Directors: after reviewing the information received from the Chair of the Supervisory Body, the Board obtains the opinion of specialist internal departments where necessary to assess the seriousness of the reported facts and the associated responsibilities. On this basis, it decides on any sanctions.

5. OPERATING PROCEDURES

5.1. GUIDING PRINCIPLES

5.1.1. PROMOTING A CULTURE OF TRANSPARENCY

To promote a culture of transparency and integrity within the company and in everyday operations, Successori Reda encourages all employees to learn and comply with the corporate protocols, requires their observance and provides for appropriate disciplinary sanctions in the event of non-compliance.

Prevention and oversight of actions are the responsibility of all employees, not only of the bodies appointed for this purpose by law or the internal organisation. Successori Reda therefore encourages anyone who becomes aware of possible breaches of corporate protocols, laws or regulations to report them, including its personnel, partners, suppliers, collaborators, customers and third parties.

This enables the company to handle such matters carefully and effectively.

5.1.2. ANONYMOUS REPORTS

To encourage widespread use of the channel, anonymous reports are accepted, provided they contain sufficient detail and are not submitted solely for defamatory purposes. However, to facilitate the investigation stage, Successori Reda encourages reports in which the reporting person identifies themselves, noting that the handling procedures are designed to ensure the highest level of confidentiality for the reporting person, in full compliance with applicable law.

5.1.3. PROTECTION OF THE REPORTING PERSON

To encourage company employees to report possible unlawful conduct, the following safeguards are adopted:

•confidentiality of the reporting person’s identity;

• the possibility of anonymity;

• prohibition of discrimination against the whistleblower.

Confidentiality of the reporting person’s identity

To protect and safeguard the reporting person, Successori Reda ensures discretion and confidentiality throughout the reporting process, from receipt through investigation to conclusion.

Where a report is submitted on paper, the following safeguards apply:

• mail is received by a third party outside the company

• the report is anonymised by removing any element that could identify the reporting person, even indirectly;

• the anonymised report is handled by the Supervisory Body.

To facilitate use of the whistleblowing channel, Successori Reda makes this reporting policy available on the company website, www.reda1865.com, in the whistleblowing section, or through QR codes displayed on company premises.

Where a report is submitted electronically, the following safeguards apply:

• the report is received by a single person outside the company, namely the Chair of the Supervisory Body or a designated member selected from the Body’s external members;

• the report’s content is separated from the reporting person’s identity, if provided;

• the reporting person’s identity is known only to the external person responsible for managing the channel;

• the report, without the reporting person’s identity, is handled by the Supervisory Body.

Possibility of anonymity

Reporting persons may submit a report anonymously through the appropriate channels if they consider this suitable. Reports identifying the reporting person are nevertheless encouraged, as communication with that person allows further details to be requested, helps substantiate the report and facilitates the investigation. Any communication between the recipient and the reporting person is subject to the same confidentiality safeguards as the original report.

Prohibition of discrimination against the whistleblower

Successori Reda undertakes to ensure protection against any direct or indirect retaliation, discrimination or penalisation against the reporting person for reasons directly or indirectly connected with the report.

All personnel involved in any capacity in the various stages of handling reports must ensure the highest level of confidentiality regarding their content and the persons concerned.

5.1.4. PROTECTION AGAINST DEFAMATORY REPORTS AND PROTECTION OF THE REPORTED PERSON

To safeguard everyone’s dignity, honour and reputation, Successori Reda undertakes to provide the greatest possible protection against defamatory reports.

Where verification establishes both that a report is unfounded and that the reporting person acted with intent and/or gross negligence, Successori Reda will take appropriate action to protect itself and its employees.

Successori Reda applies safeguards similar to those protecting the reporting person’s privacy to the person alleged to be responsible for the breach, without prejudice to applicable legal provisions.

5.2.WHISTLEBLOWING REPORTS

5.2.1. AVAILABLE CHANNELS

To facilitate the receipt of reports, Successori Reda provides employees and external stakeholders with a wide range of communication channels.

As specified in the definition of its scope, this document applies only to the whistleblowing channel, which can be accessed both by post and electronically.

A Written reports

Hand-delivered reports

Reporting persons wishing to use this channel must hand their report, optionally using the form in Annex 1, in a sealed envelope to the security guard at reception. The guard must keep the identity of the person delivering it confidential and forward the communication to the Supervisory Body as quickly as possible.

Reports by post

Reporting persons wishing to use this channel must submit a written report addressed to:

For the attention of the Supervisory Body

Via Robiolio, 25 13835 Valdilana (BI) Italy.

Whistleblowing — PRIVATE/CONFIDENTIAL

The correspondence will be opened only by the Supervisory Body formally entrusted with managing the channel.

In addition to the confidentiality obligation inherent in its role, the Supervisory Body must strictly comply with the safeguards designed to protect the reporting person’s confidentiality, as set out in section 5.1.3, Protection of the reporting person.

Electronic reports

Reporting persons wishing to use this channel must submit communications through the dedicated platform at reda.wallbreakers.it, which is also accessible from mobile devices and through QR codes displayed at various locations on company premises.

These reporting channels are suitable for protecting the reporting person’s identity electronically, as reports are sent directly to the Supervisory Body. The electronic channel provides the highest level of protection for the reporting person’s identity by applying the safeguards described in section 5.1.3. In particular, reports submitted electronically will be handled exclusively by the designated member of the Supervisory Body. If that member needs to forward the report’s content for investigation purposes, they must never disclose:

• the reporting person’s identity, if provided;

• any information that could identify the reporting person, even indirectly.

1. Oral reports

Reporting persons wishing to use this channel may communicate their report to anyone within the company. Anyone who receives an oral report must inform the Supervisory Body through the channels described above. They are also subject to the same confidentiality obligations as the Supervisory Body.

Protection of the reporting person cannot be guaranteed where a report is established to be unfounded and defamatory, thereby constituting intentional misconduct by the reporting person.

5.2.2. MATTERS THAT MAY BE REPORTED

Without prejudice to the possibility of reporting any breach, whether an act, fact or omission, that is even potentially contrary to the law or corporate protocols, reports may concern, by way of example and without limitation:

• attempted, suspected or actual acts of corruption, carried out directly, through or at the instigation of third parties, such as suppliers, consultants, collaborators, customers and intermediaries;

• any conduct considered unlawful, including conduct covered by the relevant company’s Model 231;

• unlawful and/or fraudulent activities detrimental to public bodies, customers or company assets generally;

• actions or failures to act capable of causing serious injury to workers;

• falsification of accounting, administrative or financial records intended to obtain an advantage or profit for an individual and/or the company;

• falsification or omission of checks required by external and/or internal rules, intentionally aimed at preventing unlawful conduct from being detected.

5.2.3.INVESTIGATION STAGE

The investigation stage is managed by the Supervisory Body according to predefined deadlines:

• acknowledgement of receipt within seven days of receiving the report. Acknowledgement can be sent only to non-anonymous users who have provided at least one means of contact;

• commencement of the investigation within fifteen working days of receipt of the report;

• completion of the investigation within three months of the acknowledgement of receipt.

The deadline for completing the investigation may be extended only by a formal, reasoned resolution of the Supervisory Body.

Where a report is not anonymous, the reporting person will be informed of the status of the investigation, including acceptance, closure and any action ordered, only if the report contains valid contact details, which may be an email address.

5.2.4. PRELIMINARY ASSESSMENT OF THE REPORT

The Supervisory Body carries out a preliminary assessment of whether the report is substantiated and has full access to any information necessary for this task.

If the report is manifestly unfounded, the Supervisory Body will close and archive it.

5.2.5. INVESTIGATION AND REPORTING ACTIVITIES

Where a report is generic and does not contain enough information to begin an investigation, the Supervisory Body must contact the reporting person to request further details. If the reporting person cannot be contacted or does not provide further details within fifteen working days of the request, the Body will close and archive the report.

For verification purposes, the Body may commission specialist internal departments and/or third parties to conduct further inquiries, taking care to:

• issue a formal mandate defining the scope of the work and specifying the information sought;

• omit any information that could identify the reporting person, even indirectly;

• omit information concerning the reported person unless strictly necessary for the proper performance of the assignment;

• reiterate the appointed party’s obligation to keep the processed data confidential. For parties outside Successori Reda, this obligation must be formalised in the contract for services performed on behalf of the Supervisory Body.

To ensure full transparency, reports closed as not relevant are reported to the Board of Directors and the Board of Statutory Auditors every six months, stating the subject of each report and the reasons why no further investigation was undertaken.

5.2.6. MEASURES AND SANCTIONS

Where verification of reports under this document establishes unlawful conduct attributable to employees, Successori Reda will act promptly and immediately through appropriate and proportionate measures and sanctions. These will take account of the seriousness of the conduct, its criminal relevance and the commencement of criminal proceedings where the conduct constitutes an offence under applicable national law.

Sanctions are decided by the Board of Directors on the basis of the information received from the Supervisory Body and, where deemed necessary, after obtaining the opinion of specialist internal departments. Where investigations establish intentional or negligent misconduct by third parties that have had and/or currently have dealings with Successori Reda, the company will act promptly to take all measures considered necessary for its protection.

5.3. PRIVACY

All personal data will be processed in accordance with applicable law and in the manner detailed in the Privacy Notice available on the company website or on the reporting platform.

6. DOCUMENT TRACEABILITY AND RETENTION

Traceability of the report-handling process is ensured through this policy.

Electronic records are managed exclusively through the company’s IT infrastructure. Paper records are kept outside the company by the Supervisory Body designated to manage the whistleblowing channel.

Documentation is retained for the periods and in the manner specified in the Privacy Notice.