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.

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.