WHISTLEBLOWING REPORTS

Pursuant to Legislative Decree no. 24 of 10 March 2023, Ancap S.r.l. has set up prescribed channels for receiving and managing whistleblowing reports.

WHO CAN SUBMIT A REPORT

Shareholders and persons with administrative, management, control, supervision or representation functions at the Company, even if such functions are exercised on a de facto basis; employees, trainees, self-employed workers, freelancers and consultants who work for the Company; persons who have held the above roles in the past and who acquired information regarding violations during the course of their working relationship, and persons with whom the relationship has not yet been established - for example, candidates for personnel selection or employees during a probationary period.

POTENTIAL REPORTING AREAS

The list is extremely articulate and complex. For the sake of completeness, reference is made to Legislative Decree 24/2023

1. REPORTING CHANNELS

• freephone number: 800 - 231 - 670, the call is recorded

• e-mail address 2: ancap_whistleblowing@complegal.it

• By simply making the request through one of the two channels above and leaving a contact address, the whistleblower can also request a direct meeting with an external expert tasked with managing the channel in order to submit the report in a confidential interview.



1.
As a general rule, violations of European Union regulations that harm the public interest or the integrity of the Company and of which the reporting party has become aware within the work context are potentially subject to reporting. Said violations include: unlawful conduct pursuant to Decree 231/2001 or violations of Model 231 if adopted; offences falling within the scope of application of European Union or national acts or of national acts that implement the European Union acts relating to: public procurement contracts; services, products and financial 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 and security of networks and information systems; acts or omissions that are detrimental to the financial interests of the European Union as referred to in Article 325 of the Treaty on the Functioning of the European Union; acts or omissions concerning the internal market as referred to in Article 26, paragraph 2 of the TFEU (including violations of competition and state aid rules, as well as violations relating to corporate tax rules); acts or conduct that, while not constituting an offence, frustrate the object or purpose of the provisions of the European Union acts in the areas mentioned above.
2.
To protect the confidentiality of the whistleblower, should he or she not wish to consent to the disclosure of his or her identity, written reports should be sent from personal, not company e-mail addresses (therefore, reports should not be sent from company domain emails).

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