In compliance with Legislative Decree No. 24/2023 and with particular reference to Legislative Decree 231/2001, please be informed that as of 15 December 2023, our Company has adopted the “Whistleblowing” tool.

Specifically, Whistleblowing is an additional corporate compliance instrument through which employees, collaborators, or third parties (for example, a supplier or a customer) may confidentially and securely report any misconduct encountered during their activities.

To this end, a dedicated portal has been established to receive reports, which may be submitted completely ANONYMOUSLY, as expressly provided by the aforementioned legislation.

Reports may be submitted using the channel available at the link:

https://wb-hs.mc3-innovation.it/ARXivarNextWebPortal

available within the Company’s institutional website.

Upon first access, log in with:

ID: segnalatore_eurosirel

PASSWORD: segnalatore_eurosirel

WHAT CAN BE REPORTED

Behaviours, actions or omissions that harm the public interest or the integrity of the public administration or private entity and which consist of:

• administrative, accounting, civil or criminal offences;
• unlawful conduct relevant under Legislative Decree 231/2001, or violations of the organisational and management models provided therein;
• offences falling within the scope of European Union acts or national legislation relating to the following sectors: public procurement; financial services, 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; protection of privacy and personal data; security of networks and information systems;
• actions or omissions that harm the financial interests of the European Union;
• actions or omissions concerning the internal market;
• actions or behaviours that undermine the object or purpose of the provisions laid down in EU acts.

WHAT MUST NOT BE REPORTED THROUGH THE “WHISTLEBLOWING” CHANNEL:

The following are excluded from the scope of the legislation:

• complaints, grievances or requests related to a personal interest of the reporting person or of the person who has filed a complaint with the Judicial Authority, which concern exclusively their individual employment relationship or their relationship with hierarchical superiors (therefore excluded, for example, are reports concerning labour disputes and pre-litigation phases, discrimination between colleagues, interpersonal conflicts between the reporting person and another worker or superior, reports relating to data processing carried out within the context of the individual employment relationship where no public interest or integrity of the public administration or private entity is harmed);
• reports of violations where these are already mandatorily regulated by EU acts or national laws listed in Part II of the Annex to the Decree or by national laws implementing the EU acts listed in Part II of the Annex to Directive (EU) 2019/1937, even if not listed in Part II of the Annex to the Decree;
• reports of violations relating to national security, as well as procurement concerning defence or national security aspects, unless such aspects fall within the relevant EU secondary legislation.

REPORTING CHANNELS

• internal;
• external (managed by A.N.A.C.);
• public disclosure (through the press, electronic means, or other means capable of reaching a large number of people);
• report to the Judicial or Accounting Authority.

CHOOSING THE REPORTING CHANNEL

Whistleblowers may use the external channel (ANAC) when:

• an internal reporting channel is not required in the work context, or it is required but not active, or active but not compliant with the law;
• the reporting person has already submitted an internal report and it was not followed up;
• the reporting person has reasonable grounds to believe that an internal report would not be effectively addressed or may expose them to retaliation;
• the reporting person has reasonable grounds to believe that the violation may constitute an imminent or manifest danger to the public interest.

Whistleblowers may directly make a public disclosure when:

• the reporting person has previously made both an internal and external report, or directly an external report, and no feedback has been provided within the established time limits regarding measures taken to address the reports;
• the reporting person has reasonable grounds to believe that the violation may constitute an imminent or manifest danger to the public interest;
• the reporting person has reasonable grounds to believe that the external report may expose them to retaliation or may not be effectively addressed due to specific circumstances of the case, such as the risk that evidence may be concealed or destroyed, or a founded fear that the recipient of the report may be colluding with or involved in the violation.

CONDITIONS FOR REPORTING

Reasonableness

• At the time of reporting, or of submitting a complaint to the Judicial or Accounting Authority, or making a public disclosure, the reporting person must have reasonable and well-founded grounds to believe that the reported, publicly disclosed or complained information is true and falls within the scope of the legislation.

Methods

• The report or public disclosure must be made using the appropriate channels (internal, external and public disclosure) in accordance with the criteria indicated.

Further information regarding ANAC’s responsibilities is available on the Authority’s website (https://www.anticorruzione.it/) in the dedicated section.

PLEASE NOTE:

ANAC has established fines ranging from €500 to €2,500 for whistleblowers if criminal liability for defamation or slander is established.

To proceed, the whistleblower may access the reporting link only after clicking a confirmation such as:
“I fully understand the above and intend to proceed with the report.”