Reports of violations of Whistleblowing regulatory provisions

The Whistleblowing Decree (Decree no. No. 24 of 10 March 2023) aims to protect people who report breaches of national or European Union regulatory provisions that harm the public interest or the integrity of the public administration or private entity, of which they have become aware in your work context.

PIETRO BARBARO S.p.A. promote the dissemination and use of whistleblowing as a fundamental measure to prevent and combat corruption phenomena and illegal conduct, as well as to protect the authors of the reports in accordance with the provisions of current legislation and of the Organizational Model under the Decree 231/01.

The Whistleblowing Policy regulates the process of sending, receiving, analyzing and processing, including archiving and deletion, of Reports, originating or transmitted by anyone, even in confidential or anonymous form, as well as the protection of the Whistleblower and the Persons Involved.

Read the Whistleblowing policy

The protection measures provided apply to the Whistleblower that is the person who reports the breaches of which he has become aware in his work context:

• employees
• self employed; freelancers and consultants
• volunteers and interns
• shareholders and persons who perform administration, management, control and supervisoryor representation functions
• candidates; probationary workers
• former employees; facilitators
• relatives or work colleagues of the whistleblower
• subjects owned by the Whistleblower or who operate in the same work context as the whistleblower

“Breaches” are identified as behaviours, acts or omissions detrimental to the public interest or the integrity of the public
administration or the Company of which the Whistleblower has become aware in his/her working context and consist of:

1. administrative, accounting, civil or criminal offences
2. significant unlawful conduct pursuant to Legislative Decree 231/2001, or breaches of the organization and management models provided for therein
3. offences falling within the scope of European Union or national acts relating to the following areas (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 protection of personal data and security of network and information systems)
4. acts or omissions affecting the financial interests of the Union
5. Acts or omissions concerning the internal market, referred to in art. 26, par. 2, TFEU, including infringements of EU competition
   and state aid rules, as well as corporate tax
6. Acts or behavior that frustrate the object or purpose of the provisions referred to in EU acts in the sectors indicated in points 3), 4) and 5) above

IT platform

Through the IT platform accessible from the Company’s website,
https://pbgroup.integrityline.com

Reports can be sent:

• in written form, by filling out the appropriate form;
• voice messaging and morphing system

Paper missive

Paper letter sent to the attention of the Whistleblowing Committee
with the words PERSONAL CONFIDENTIAL to the following address:
PIETRO BARBARO Via Jacopo Peri 1 – 00198 – Rome (RM) Italy

Direct meeting

Direct meeting with the Whistleblowing Committee for the management of reports,
set within a reasonable time at the explicit request of the Whistleblower

The following requirements must be complied with to submit reports:

• a single channel must be used to present the report/communication and to carry out subsequent integrations
• the use of the platform is the priority channel
• no duplications of the same report must be submitted

Reports through external channels can be made under certain conditions to the National Anti-Corruption Authority (ANAC):

• in written form via an IT platform accessible from the ANAC website: https://www.anticorruzione.it/-/whistleblowing, by completing the Form for reporting illicit conduct pursuant to Legislative Decree no. 24/2023.
• or orally through telephone lines or dedicated voice messaging systems or direct meeting set within a reasonable time, at the request of the Whistleblower

The Whistleblower may make information on Breaches public through:

• the press;
• electronic means;
• other means of diffusion capable of reaching a large number of people (e.g. TV, social networks).

The Company will adopt the most appropriate disciplinary and/or legal measures to protect its rights, assets and image against anyone who interferes with, or improperly uses, the Whistleblowing channels set up for reportingBreaches:

• violating the measures to protect the Whistleblower or the Person Involved or otherwise mentioned in the report
• carrying out retaliatory or discriminatory actions against the Whistleblower as a result of his reporting
• making reports with malice or gross negligence that prove to be unfounded or opportunistic and/or for the sole purpose of slandering, defaming or causing unfair damage and/or prejudice to the Person Involved or to other subjects mentioned in the report

The Company guarantees the absolute confidentiality of the identity of the Whistleblower, the Person Involved and the person mentioned in the report, the latter until the conclusion of the proceedings initiated due to the report, without prejudice to any further form of liability provided by law.

Who, under the conditions set out in the Whistlebowing Policy, reports:

• is protected by the prohibition of retaliation, even indirect, against him (including dismissal, suspension, demotion or failure to promote, demotion, negative references, intimidation or harassment, reputational damage, etc.)
• benefits from support measures provided by Third Sector bodies (i.e., free information, assistance and consultancy on reporting methods and protection from retaliation, on the rights of the person involved, as well as on the methods and conditions of access to legal aid State)