With a view to compliance with the reference legislation (Legislative Decree 24/2023), the Company has adopted a Whistleblowing procedure through which it is possible to report to the competent bodies, in a confidential and protected manner, any offences encountered during one's work activity.

Whistleblowing reports consist of written or oral communications of information on violations, or conduct, acts or omissions that harm the public interest or the integrity of the Company and that are attributable to:

• administrative, accounting, civil or criminal offences;

• offences falling within the scope of European Union or national acts relating to the following areas: public procurement, services, financial products and markets and prevention of money laundering and terrorist financing, product safety and compliance, transport safety, environmental protection, radiation protection and nuclear safety, food and feed safety and animal health and welfare, public health, consumer protection, privacy and protection of personal data and security of networks and information systems;

• acts or omissions affecting the financial interests of the Union;

• acts or omissions affecting the internal market;

• acts or conduct that frustrate the object or purpose of the provisions of Union acts.

Reports are excluded:

• linked to a personal interest of the reporting subject or concerning individual employment relationships;

• concerning national security and defence

• relating to violations already mandatorily regulated in certain special sectors (financial services, prevention of money laundering, terrorism, etc.);

The use of this procedure is limited to cases in which the reporting party is in good faith and the report is based on precise and concordant facts. The Company encourages reports in good faith but does not accept false or vexatious statements, mere suspicions, rumours, complaints or claims of a personal nature. In such cases, the Company reserves the right to take appropriate civil, criminal and disciplinary action against anyone who abuses the whistleblowing procedure.

Reports can be made through the following channels

• in written form: through the use of an IT platform made available by the Company which provides a guided path for making the report, by accessing the SIGNALING PORTAL, a special manual is also available.

• orally: by means of a telephone channel integrated into the IT platform which can be accessed by calling 0536040210, after listening to the recorded message the reporter can make the report. The telephone line is common to all Italian companies of the Concorde Group obliged to have a Whistleblowing procedure, therefore the whistleblower must indicate the specific company involved in the report.

The whistleblower may be summoned for further investigation of the report. The Company ensures protection against any form of retaliation, in particular, there is a ban on retaliatory or discriminatory acts against those who report conduct constituting a crime or offence, and there are specific sanctions against those who violate the measures to protect the reporter or those who make reports that prove to be unfounded.

For further information, see the extract from the Whistleblowing Policy.

In order to guarantee the right to protection of the personal data of the persons making the report, the reported person and the persons involved, the acquisition and management of reports take place in full compliance with the provisions of the GDPR (General Data Protection Regulation) approved by EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016.

For more information please refer to the following links: