Whistleblowing Reports

Legislation

Legislative Decree No. 24 of 10 March 2023 (“Whistleblowing Decree”) implemented Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 (“Whistleblowing Directive”) on the protection of persons reporting breaches of Union law and laying down provisions on the protection of persons reporting breaches of national regulatory provisions.

Whistleblowing policy

The Company has adopted a Procedure to provide clear operational guidance regarding the subject matter, recipients, methods of transmission and management of reports concerning violations included in the scope of the whistleblowing decree.

The internal signaling channel

Reports must be transmitted through the appropriate internal channel accessible directly from the browser to the following address: https://cmcgruppo.whistletech.online

The IT platform allows you to make reports in written or oral form, recording a voice message that will be encrypted and morphized in order to make the reporter’s voice unrecognizable.

Also through the IT platform, the reporter may request a direct meeting from the reporting channel manager, which will be scheduled within a reasonable time.

The application ensures, through the use of encryption tools, the confidentiality of the identity of the reporting person, the person involved and the person otherwise mentioned in the report and the related documentation.

The data is stored on secure servers outside the corporate network.

The external signaling channel

In the cases provided for by the whistleblowing decree and indicated by the Procedure, the reporter can resort to the external channel managed by ANAC (www.anticorruzione.it) and can be reached at the following address: https://www.anticorruzione.it/-/whistleblowing.

Public disclosure and complaint to the Authorities

Always in the cases provided for by the whistleblowing decree and the Procedure, the reporter may make a public disclosure, through the press and other means of communication and/or dissemination, such as social networks.

The possibility of reporting to the National Judicial and Accounting Authorities remains firm.

Personal data processing

It is recommended that you review the specific information on the processing of personal data prepared pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”).