The Portal for Reporting

24 ORE Cultura S.r.l. (the “Company”) puts the Whistleblowing Portal (the “Portal”) available to those who intend to make, in good faith, a report of behaviors or events that may be configured as relevant unlawful conduct pursuant to Legislative Decree 231/2001 or violations of the 231 Model (and of the Code of Ethics of the 24 ORE Group and/or of the procedures of the internal regulatory system of the 24 ORE Group), or of company procedures or in any case not compatible with ethically correct behavior. Reports must be made to protect the public interest and the integrity of the Company.

Transmission mode

The Portal allows the reporter to choose whether or not to provide his or her identity; access to the Portal is managed on a no-log in order to prevent the identification of the reporter who intends to remain anonymous. In any case, the reporter will be able to supplement his or her personal details at a later time, again through the Portal.

After logging in, the reporter will be guided in filling out a questionnaire that will allow him or her to provide, in written or oral form, the elements characterizing the report (facts, context, etc.). The reporter is also given the option, again through the Portal, to request an in-person meeting.

When sending the report, the Portal will issue the reporter with a unique identification number (ticket). This number, known only to the reporter, cannot be recovered in any way in case of loss. The ticket will be used by the reporter to access, again through the Portal, his or her report in order to: monitor its progress; enter additional elements to substantiate the report; supplement his or her personal details; and submit or answer any follow-up questions. The Portal allows, in fact, to establish a virtual conversation between reporter and recipient, guaranteeing the necessary confidentiality and, at the discretion of the reporter, anonymity.

Who handles the report

The task of receiving reports is assigned to the Company’s Internal Audit.

The management of reports for the Company is carried out by the Company’s Supervisory Board.

An acknowledgement of receipt will be sent to the reporter within 7 days from the date of submission through the Portal. This will then be followed by further information, again through the Portal, upon completion of the investigation of the reported event, but no later than 3 months.

Protection and accountability of the reporter

No retaliation or discrimination, whether direct or indirect, may result against anyone who has made a report in good faith. In addition, sanctions are provided against those who violate the whistleblower protection measures.

Penalties are provided for the whistleblower, where possible, in the case of reports made with malice or gross negligence or that turn out to be false, unfounded, with defamatory content or otherwise made for the sole purpose of harming the Company, the whistleblower or persons affected by the report. The Company may also take appropriate legal action.

Protection of the reported

The report is not sufficient to initiate any disciplinary proceedings against the reported person. If, as a result of concrete findings acquired with regard to the report, it is decided to proceed with the investigative activity, the reported person may be contacted, who will be guaranteed the right to provide any necessary clarification.

Recommendations

The Portal is intended for use by those who, in good faith and in accordance with ethical principles of integrity, report conduct that potentially does not comply with laws and regulations or with GRUPPO 24 ORE’s internal principles and procedures, of which they have become aware. Such reports are also accepted anonymously. The Company will prosecute the authors of reports made in bad faith, with defamatory intent or that are not in the proper spirit of cooperation towards the company.

The protections afforded to the Whistleblower do not apply to disputes, claims or requests related to an interest of a personal nature of the Whistleblower that pertain exclusively to his or her individual work relationships, or inherent to his or her work relationships with hierarchically subordinate figures. They are therefore invited NOT to use the Portal with reference to such matters; in general, the 24 ORE GROUP urges its employees to resolve any labor disputes, where possible, through dialogue, even informally, with their colleagues and/or their direct supervisor.

Similarly, please do not use the Portal for complaints, requests for assistance and other questions of a commercial nature: for these purposes the appropriate sections on the websites of the 24 ORE GROUP companies or customer service (02 30300600) are available.

Reports must be made in a spirit of responsibility, be of interest to the common good, and fall within the types of nonconformities for which the system has been implemented.

Please refrain from reports that do not fall under the above cases.

Privacy Protection

All reports are strictly confidential. Any personal data contained in the report will be treated in accordance with the data protection regulations and the GDPR Policy adopted by the Company. For more information please see the “Privacy Policy” section.

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