WHISTLEBLOWING

WHISTLEBLOWING - REPORTS OF VIOLATIONS

According to D.Lgs. n.24 of 10 March 2023, Altergon encourages anyone who, in the context of work, has become aware of hypotheses of violations of the Organization, Management and Control Model of Altergon (Model 231), the Code of Ethics, the Anti-Corruption Guidelines of Altergon, or other hypotheses of violation of the law that could put Altergon business or reputation at risk or that could cause damage to third parties.

REPORTING REQUIREMENTS

Each report must contain the following elements:

• the personal details of the whistleblower, in the event that the whistleblower does not opt for being anonymous;
• a clear and complete description of the facts being reported;
• if known, the circumstances of time and place in which they were committed;
• if known, personal details or other elements (such as the qualification and the service in which a reported person carried out the activity) that allows for identification of the subject (s) who has/have carried out the reported facts;
• the indication of any other persons who may be able to report on the facts being reported;
• an indication of any documents which may confirm the validity of the facts being reported;
• any other information that may be useful when assessing the facts reported.

It should be noted that:

• reports based on mere suspicion or rumors, unreliable, will not be taken into account;
• anonymous reports will only be taken into account if they meet the above requirements;
• reports concerning disputes, claims or requests related to a personal interest of the whistleblower, that relate exclusively to the whistleblower’s individual employment relationship, including, but not limited to, labor disputes or friction between colleagues, are not allowed.

INTERNAL REPORTING CHANNELS

Reports can be submitted using one of the following internal reporting channels:

• Mail: Altergon Italia S.r.l., Zona Industriale A.S.I. - 83040 Morra De Sanctis (AV). To the attention of “Organismo di Vigilanza” (Supervisory Board), marked "Confidential"
• Web: https://altergon.whistlelink.com – Written or oral reports

Oral reporting is also permitted, at the request of the whistleblower, through a direct meeting with “” of Altergon to be requested using the channels indicated above.

Each report will be evaluated to determine its suitability for further asessment. Reports will always be managed guaranteeing the confidentiality of the whistleblower and the prohibition of retaliation against the whistleblower. In the case of anonymous reports, the whistleblower may be asked to reveal his identity, which is with the guarantee of confidentiality and the protections provided for by the UE Directive 2019/1937 on Whistleblowing.

EXTERNAL REPORTING CHANNELS

In some cases, you can send the report to ANAC (Autorità Nazionale Anticorruzione - National Anti-Corruption Authority).

It is possible to do so ONLY IF one of the following conditions is met, of which the whistleblower must be able to have evidence:

• following a report, made through the use of the Company's internal channel, the same was not managed;
• the whistleblower has reasonable grounds to believe that, if he made an internal report, it would not be effectively followed up or that the report could determine the risk of retaliation;
• the whistleblower has reasonable grounds to believe that the breach may constitute an imminent or manifest danger to the public interest.

Finally, public disclosure through the press or electronic means or means of mass communication capable of reaching a large number of people can be used ONLY IF one of the following conditions is met, of which the whistleblower must be able to have evidence:

• the whistleblower has already made an internal and external report, or has directly made an external report and has not received feedback within the deadlines provided for;
• the whistleblower has reasonable grounds for believing that issue, which the whistleblower wishes to disclose, may constitute an imminent or manifest danger to the public interest;
• the whistleblower has reasonable grounds to believe that external reporting may involve a risk of retaliation or may not be effectively followed up due to the specific circumstances of the case, such as those where evidence may be concealed or destroyed, or where there is a well-founded concern that the whistleblower may be colluding with or involved in the breach.