POLICY WHISTEBLOWING

A report means any communication received pertaining to the Internal Control System and concerning conduct referable to employees, members of corporate bodies (Board of Directors, Board of Statutory Auditors) or other governing bodies (SB), auditing firms and third parties (partners, customers, suppliers, consultants, collaborators, etc.) put in place in violation of the Code of Ethics, laws, regulations, provisions of the Authorities, internal regulations, Model 231, or any critical issue or matter that may in any case cause damage or harm, even if only in terms of image, to the Company. In particular, communications pertaining to non-compliance with external laws and regulations, principles contained in the Code of Ethics and company procedures, illegal conduct pursuant to Legislative Decree 231/01 and/or violations of Model 231, possible acts of corruption (active or passive) are considered as such.

From the link below you can open the online form that allows you to submit a report in complete confidentiality through the Reports platform.

https://fiocchi.segnalazioni.net/

Alternatively, you can send an e-mail to [email protected] that contains:

• Data of the reporter (first name, last name)
• Description of the report with indication of:

• Business area where the incident occurred and other indications to circumscribe the incident
• Period in question and other indications to circumscribe the incident
• Physical location where it occurred
• Name, surname, qualification of the person who (potentially) committed the act (in case of persons outside Fiocchi, please specify)
• Any other individuals who can report on the fact

There is also provision for the physical deposit of the Report in a sealed envelope marked “confidential/personal” in the special Report box established at FIOCCHI headquarters. Specifically, the box is located under the bulletin board in the turnstile area at the entrance.

From this page, an employee or third party (e.g., a supplier) may report alleged misconduct or findings of alleged irregularities or violations of which he or she has become aware by reason of his or her employment relationship and role. For example:

• Corruption
• Theft
• Mobbing
• Violent or harassing behavior
• Violation of the Code of Ethics
• Violation of tender procedure and other assignments
• Violation of personnel selection and hiring procedure
• Conflict of interest
• Violation of 231 Model
• Public Security
• Health, Safety and Environment

Complaints or grievances related to business activities (e.g., billing problems or other business disputes) are not treated as Reports.

Any form of retaliation or discrimination against those who make reports in good faith is prohibited. The Company reserves all action against anyone who makes untruthful reports in bad faith.