Whistleblowing Policy

1. Introduction

This whistleblowing policy was developed by Metaltronica S.p.A. with the aim of promoting an ethical, responsible and transparent work environment. We recognize the importance of encouraging the disclosure of information regarding behavior that may be illegal, unethical, or non-compliant with company policies. Whistleblowing provides a secure and confidential platform through which employees and other stakeholders can report legitimate concerns.

2. Purpose

The purpose of this policy is to:

Promote timely and responsible reporting of illegal or unethical behavior.
Protect whistleblowers from retaliation or discrimination.
Ensure confidentiality and anonymity of reports, if required and permitted by law.
Conduct thorough and objective investigations into all reports received.
Implement corrective and preventive measures when necessary.

3. Scope of Application

This policy applies to all Metaltronica S.p.A. employees, suppliers, customers and any other interested party who wishes to report concerns related to the company’s activities.

4. Types of Reports

Reports may concern, but are not limited to:

Illegal or criminal behavior.
Violations of laws, regulations or company policies.
Fraud or suspicious financial activity.
Abuse of power or discrimination in the workplace.
Threats to the health and safety of employees or the public.
Unethical or unprofessional behavior.

5. Reporting Channels

To ensure a secure and confidential reporting process, Metaltronica S.p.A. offers the following channel which optionally offers the possibility to report anonymously:

https://metaltronica.trusty.report

6. Whistleblowing Management Procedure

All reports received will be treated with the utmost confidentiality and objectivity. The reporting management procedure includes:

Registration and initial evaluation of the report.
Assignment of a dedicated investigation team.
In-depth investigation and collection of evidence/documentation.
Protecting the whistleblower’s identity, if required and permitted by law.
Communication of the results of the investigation and the actions taken.
Implementation of corrective or preventive measures, if necessary.

7. Whistleblower Protection

Metaltronica S.p.A. will not tolerate retaliation against those who make reports in good faith. Any attempt to punish, discriminate against or take negative action against the whistleblower
will be considered a serious violation of company policy and could lead to disciplinary action, including termination of employment.

8. False Reporting

Reports that are intentionally false or made in bad faith will be subject to disciplinary action and may result in legal consequences.

9. Review and Updates

This whistleblowing policy will be periodically reviewed and updated as necessary to ensure its effectiveness and relevance over time.

Last revised 30 August 2023 by the manager appointed by Metaltronica S.p.A.