WHISTLEBLOWING REPORTING CHANNEL

The European Union, with Directive 2019/1937, has renewed the legislation concerning the protection of persons who report breaches of Union law, in order to create a minimum standard for the protection of whistleblowers’ rights in all Member States.

Santex S.p.A. considers compliance with the ethical and transparency principles it has adopted as fundamental, as is compliance with the rules and regulations in the countries in which it operates.

In this context, it has implemented a process for the collection and management of reports (so-called “Whistleblowing”) that pursues the objective of providing the whistleblower, i.e. the person who reports violations, with clear operational indications on the subject, contents, recipients and methods of transmission of reports.

The whistleblowing management process is an integral part of the Organisational, Management and Control Model pursuant to Legislative Decree no. 231/2001 of Santex S.p.A.

Reports shall concern all violations of national or European Union regulations that harm the public interest or the integrity of Santex S.p.A., as well as illegal conduct relevant pursuant to Legislative Decree no. 231/2001 or violations of the organisational management models.

Reports do not concern private matters or grievances of a personal nature of the reporting person or violations already mandatorily regulated by European Union or national acts. It also does not include reports of violations relating to national security, or to contracts relating to aspects of national defence or security, unless such aspects are covered by relevant secondary European Union law.

The following reports can be made specifically:

• Violations of national or European provisions consisting of offences concerning the following areas: public procurement, services, products and financial markets, and the prevention of money laundering and the financing of terrorism, 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, privacy and personal data protection, and the security of networks and information systems;
• Violations of European provisions consist of: (i) acts or omissions that are detrimental to the financial interests of the Union; (ii) acts and omissions that concern the internal market; (iii) acts and conduct that frustrate the object or purpose of the provisions of Union acts in the aforementioned areas;
• Illegal conduct relevant under Leg. 231/2001, or violations of organisational and management models;
• Violations or alleged violations of the values and principles of conduct contained in the Code of Ethics, including reports concerning harassment and/or alleged harassment in the workplace by colleagues, superiors and/or other individuals collaborating with the company, with regard to both the reporter and third parties, of which the reporter has become aware;
• Violations likely to cause financial damage to the company as well as damage to the health and safety of individuals working within them;
• Discrimination, harassment, violence and bullying.
  
  

Santex S.p.A. has set up an internal written and oral whistleblowing channel through the My Whistleblowing add-on to the My Governance software (a Zucchetti Group company), which guarantees the confidentiality of the whistleblower, the person involved and the person in any case mentioned in the report, as well as the content of the report and the relevant documentation.

An internal management committee for the examination of reports has been identified and has been duly appointed and authorised.

This channel is exclusively dedicated to reports of offences and violations as regulated in Legislative Decree No. 24 of 10 March 2023. Obviously, reports must be documented and have a serious basis in order not to incur, on the contrary, the offence of defamation committed by the reporter in the event of an unfounded or non-existent report.

If you are an employee of Santex S.p.A., please also consult the appropriate procedure available on the Company Intranet.