Whistleblowing

Cimbali Group S.p.A. takes great care to ensure that its activities and business are conducted with integrity, in a professional and fair manner, maintaining high ethical standards and complying with local and international regulations.

“Whistleblowing” (hereinafter the “Report”) means any report, coming from anyone, concerning any behavior, occurring in the performance of work activities or having an impact on the same, referable to the Personnel of Cimbali Group S.p.a. or companies belonging to its group (hereinafter the “Company”) and/or Third Parties in violation of or otherwise non-compliant with laws, regulations, the Code of Ethics, the Organizational Model 231, as well as the system of rules and procedures in force in the Company, learned in the working context of the reporter.

With the aim of promoting and strengthening its commitment to conducting its business activities with honesty and integrity, the Company provides its stakeholders with a reporting system that allows them to report, with the guarantee of confidentiality, information about conduct or omissions related to the work environment that may harm the integrity of the Company in accordance with D.Legislative Decree No. 24 of March 10, 2023 (“Implementation of EU Directive 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law and on provisions concerning the protection of persons who report breaches of national laws“).

Subject of the Report

Reports may relate to information, including well-founded suspicions, learned within one’s work environment, of potential or actual violations, or conduct designed to conceal violations, of:

(i) administrative, accounting, civil and criminal offenses that harm the interests, decorum and integrity of the entity;

ii) illegal conduct relevant to Legislative Decree 231/2001 or violations of the 231 Model, internal procedures relevant to the 231 Model and the Code of Ethics;

(iii) offenses falling within the scope of EU legislation in the areas of public procurement, services, products and financial markets, prevention of money laundering and terrorist financing, product safety and compliance, transportation safety, environmental protection, radiation protection and nuclear safety, food and feed safety and animal health and welfare, public health, consumer protection and personal data protection, and network and information system security;

(iv) acts or omissions that harm the financial interests of the European Union;

(v) acts or omissions concerning the internal market.

Excluded from the object of the reports are disputes, claims or requests related to a personal interest of the reporting person that pertain exclusively to his or her individual labor relations, i.e., inherent in labor relations with hierarchically subordinate figures (e.g. reports concerning labor disputes and pre-litigation stages, discrimination between colleagues, interpersonal conflicts between the reporting person and another worker or with hierarchical superiors, reports concerning data processing carried out in the context of the individual labor relationship in the absence of injury to the interest or integrity of the Company).

The report must be made in good faith and must be suitable to provide all the elements within the knowledge of the reporter (e.g., detailed description of the facts, the manner in which it came to the knowledge of the facts, indication of the persons involved and other persons who can report on the facts), so as to allow due verification to confirm the validity of the facts being reported, attaching or indicating any useful documentation.

Whatever the manner in which the report is made, it will ensure the confidentiality of the reporter and, where required, anonymity, and will handle confidentially and in compliance with applicable legal regulations, all information related to the case.

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The Company encourages anyone, employees and third parties (including but not limited to Business Partners, Suppliers, Customers, collaborators and in general Stakeholders) to report, even anonymously, in good faith and without fear of retaliation, any potential illegitimate behavior (as specified above), using one or more of the following reporting channels:

– “Reporting – Whistleblowing” web platform available by clicking HERE

– e-mail to the Supervisory Board: odv@cimbaligroup.com