Gaber S.p.A., aware of the importance of activating appropriate reporting channels to protect the integrity of the Company and ensure compliance with the principles of legality, fairness, and transparency, also towards third parties, in the conduct of business activities, has activated specific corporate reporting channels in accordance with Legislative Decree No. 24/2023, implementing EU Directive 2019/1937. With this Notice, Gaber S.p.A. intends to promote the widest dissemination among all Recipients of any useful information on the channels, procedures, and prerequisites for making both internal and external reports.   WHO CAN MAKE A REPORT Persons operating in the corporate work context in the capacity of: employees; freelancers and collaborators who carry out their work at the Company; freelancers and consultants who provide their services at the Company; volunteers and interns, paid and unpaid, who provide their services at the Company; shareholders and persons with administrative, management, control, supervision, or representation functions, even if such functions are exercised de facto, at the Company, even when the legal relationship has not yet begun, if the information on violations was acquired during the selection process or in other pre-contractual phases or during the probationary period or after the termination of the legal relationship if the information on violations was acquired during the relationship itself.   WHAT BEHAVIORS CAN BE REPORTED Relevant Reports are those concerning behaviors, acts, or omissions that harm the public interest or the integrity of the Company of which the whistleblower became aware in the work context and consist of: unlawful conduct relevant under Legislative Decree No. 231/2001 and violations of Model 231, such as, by way of example, corrupt behavior towards the Public Administration, violations in the field of Health and Safety at Work, violations of Environmental regulations. It is noted that such reports can only be made through internal reporting channels; unlawful acts falling within the scope of the European Union's acts relating to the following sectors: public procurement; financial services, products, and markets and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; public health; consumer protection; privacy and personal data protection and network and information systems security; acts or omissions that harm the financial interests of the European Union, such as fraud, corruption, and any other illegal activity related to Union expenditure; acts or omissions concerning the internal market, including violations of EU competition and state aid rules as well as corporate tax matters, free movement of goods, people, services, and capital; acts or behaviors that undermine the object or purpose of the provisions of the European Union's acts in the above sectors. In this context, so-called abusive practices that contravene the protection of free competition (adoption of predatory pricing, target discounts, tied sales, etc.) should be included. Reports related to a personal interest of the whistleblower that pertain exclusively to their individual employment relationships, or concerning their employment relationships with hierarchically superior figures or aspects of the life of the reported subject, without any direct or indirect connection with the corporate and/or professional activity, are excluded from the scope of the regulation. Also excluded are reports that are clearly unfounded, information already entirely in the public domain, information acquired solely based on unreliable rumors (so-called corridor rumors), or pretextual, defamatory, slanderous, or aimed solely at damaging the reported party.   CHARACTERISTICS OF THE REPORT To allow for adequate verification activity, it is necessary that the report be as detailed as possible to allow for the reconstruction of the fact and the verification of the validity of what is reported. In particular, the following should be indicated: the identifying data of the reporting person (name, surname, place, and date of birth) and in the case of a direct meeting, a contact where to receive the acknowledgment of receipt of the report and subsequent feedback, as well as any requests for additions and clarifications; the time and place circumstances in which the fact subject to the report occurred and, therefore, a description of the facts subject to the report, specifying the details related to the circumstantial news and, where present, also the ways in which the facts subject to the report were learned; the identity or other elements that allow the identification of the possible subject to whom the reported facts are attributed; any attached documents; any subjects potentially aware of the facts. In the case of receiving anonymous reports, it is specified that they will be considered and treated as ordinary reports only if they are precise, detailed, and supported by appropriate documentation, even with the same internal procedures provided for whistleblowing reports.   INTERNAL REPORTING CHANNELS To allow the transmission of Reports, the Company, after consulting the representatives or trade unions, activates and keeps open the channel in written form through the Online platform: https://whistleblowing.dataservices.it/GABER If requested by the whistleblower, a direct meeting with the Channel Manager can be arranged. The direct meeting is held exclusively by the Channel Manager in a confidential manner and through the drafting of the specific reporting form. Gaber S.p.A., in full compliance with the Whistleblowing Decree, ensures that the above channels guarantee the confidentiality of the identity of the reporting person, the person involved, and the person mentioned in the report, as well as the content of the report and the related documentation. The management of the reporting channel is entrusted to Lawyer Filippo Baggio (the “Channel Manager”).   REPORT MANAGEMENT PROCEDURES The Channel Manager, upon receiving the report, carries out the following activities: issues the whistleblower with an acknowledgment of receipt of the report within seven days from the date of receipt; maintains communications with the reporting person and may request additional information if necessary; diligently follows up on the reports received by activating the subjects responsible for managing the report; provides feedback to the whistleblower within three months from the date of the acknowledgment of receipt or, in the absence of such acknowledgment, within three months from the expiration of the seven-day deadline from the submission of the report. Such feedback may also be interlocutory if the investigation is not yet completed. Once the investigation is completed, the results must still be communicated to the whistleblower. For the proper handling of the report, internal or external subjects may be involved, considering the specific technical and professional skills required, who are not in conflict of interest and who will still be bound by the confidentiality obligations provided by the regulation. At the end of the investigation, if the report is founded, the Channel Manager will address the competent internal bodies/functions for the relevant follow-ups for the activation of preventive, corrective, or disciplinary actions against the reported party.   THE EXTERNAL REPORTING CHANNEL (ANAC) To resort to the reporting channel established by ANAC, certain conditions must be met. In particular, the whistleblower can access the external procedure only if one of the following conditions applies: in their work context, the internal company reporting channel is not active or, even if activated, is not compliant with Legislative Decree No. 24/2023; they have already made an internal report and it has not been followed up; they have reasonable grounds to believe that, if they made an internal report, it would not be effectively followed up or the same report could pose a risk of retaliation; they have reasonable grounds to believe that the violation could pose an imminent or obvious danger to the public interest. Any retaliations suffered can also be reported to the same channel. See https://www.anticorruzione.it/-/whistleblowing Data will be processed in accordance with the provisions of GDPR No. 679/2016 and Legislative Decree No. 24/2023. See Privacy Whistleblowing. CLICK HERE TO SUBMIT YOUR REPORT