WHISTLEBLOWING

Introduction to Whistleblowing

AIRAGA RUBINETTERIE S.P.A. promotes an open corporate culture based on ethics, transparency, and responsibility, and inspired by corporate values: for this reason, it asks its members, such as directors, executives, supervisory bodies, managers, employees, and other collaborators, as well as all its partners, to operate in full compliance with the laws and regulations, Code of Ethics, and human rights.

The Company strongly encourages its stakeholders to report (whistleblowing) any improper, dishonest, or illegal activity—whether potential, highly probable, or already committed—as well as any behavior that could cause damage or harm, including damage to the image, of AIRAGA RUBINETTERIE S.P.A.

To this end, the company has implemented specific rules and a management process in accordance with the “Whistleblowing” legislation (Legislative Decree 24/2023) to provide potential whistleblowers with secure channels that guarantee the confidentiality of their identity and the information contained in the report, as well as their protection from any retaliation.

Report management

AIRAGA RUBINETTERIE S.P.A. has appointed a Committee of External Experts in whistleblowing regulations, organizational models pursuant to Legislative Decree 231/01 and management systems, EU law, industrial relations, and labor law to manage whistleblowing reports. This committee is characterized by its autonomy, impartiality, and independence with respect to the processes that may be the subject of reports. It has also made available an external digital platform, managed by a specialized third party, in order to ensure the effectiveness and confidentiality of the reporting process and to provide broad and indiscriminate access to all those who wish to make a report. The Company encourages whistleblowers to give preference to identified and non-anonymous reports in order to streamline investigations and make them more effective, although anonymous reports are also accepted, provided they are fully substantiated.

In order to ensure the effectiveness of the reporting process and provide broad and indiscriminate access to all those who wish to make a report, it has made available a variety of alternative communication channels, such as:

  • written report: using the Globaleaks software platform (https://www.globaleaks.org/it), which can also be accessed via the Company’s public website: whistleblowing.airaga.com

  • Written reports: registered mail with return receipt to be addressed to: c.a. COMITATO WHISTLEBLOWING – STRETTAMENTE RISERVATA – presso Confindustria Novara Vercelli Valsesia — Corso Cavallotti, 25 – 28100 — Novara; The report must be placed in two sealed envelopes: the first containing the reporter’s identification details; the second containing the report, so as to separate the reporter’s identification details from the report. Both envelopes must then be placed in a third sealed envelope bearing the above addressee on the outside.

  • Oral report: face-to-face meeting or telephone contact with the Committee by appointment, which can be requested by the reporter via email with confirmation of receipt to [email protected]. In this case, hearings with the reporter may also take place outside the company premises.

The functionality of the aforementioned communication channels is also verified by the Whistleblowing Committee, which must be contacted in the event of any malfunctions.

Documentation

The whistleblowing documentation of AIRAGA RUBINETTERIE S.P.A. is available at the following links:

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