whistleblowing

Legislative Decree 24/2023: Reporting of Regulatory Violations in the Company (Whistleblowing)

Baldinini S.r.l., in compliance with the provisions of Legislative Decree 24/2023, has established specific confidential channels (see below) that can be used to report violations of national or European Union regulations that may occur within the company.

It is hereby clarified that the confidential channels listed below should not be used to submit complaints, claims, personal requests, or to report disputes among colleagues, internal organizational issues, and similar situations.

Reports must be detailed and based on specific and consistent elements, and should contain, as much as possible, the information necessary to identify the perpetrators of the misconduct.

The reporting party is therefore required to clearly and fully provide all relevant information to conduct the necessary checks and assessments to evaluate the validity and objectivity of the report.

The undersigned Company guarantees the confidentiality of the identity of the reporting party and the reported party in accordance with the applicable regulations. However, reports can also be made anonymously.

All reports, including anonymous ones, are carefully examined and managed by specifically authorized individuals. Where possible, appropriate feedback is provided to the reporting party within the legal timeframe.

Personal data is processed in compliance with European Regulation 2016/679 and Legislative Decree 196/2003, to the extent still applicable. In this regard, please carefully review the information provided below.

Reports can be made/submitted through the following confidential channels, which are alternative to each other:

• by calling the toll-free number: 800.033.720 - active from Monday to Friday - 9:30 am/12:30 pm;
• by filling out the form on the reporting management portal, accessible from the following link: www.whistleblowingfacile.it;
• by writing to the external consulting company: Winger S.r.l. - Legislative Decree 24/2023 Reporting Office - Via Piccard 16/G, 42124, Reggio Emilia (RE);
• by scheduling an appointment with a specially appointed professional, at the offices of the external company Winger S.r.l., located at Via Piccard 16/G, Reggio Emilia (RE).

Information to the reporting party provided pursuant to Article 13 of European Regulation 2016/679

Given that following the report you made pursuant to Legislative Decree 24/2023, our company may collect and process your personal data, we hereby specify the following definitions provided by European Regulation 2016/679:

Personal data: any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person; Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction. Having stated the above, pursuant to Article 13 of European Regulation 2016/679,

we inform you that the collection and processing of personal data will be carried out by the undersigned company in accordance with the following:

1. Purpose: the data will be processed solely for managing the report in accordance with Legislative Decree 24/2023, to fulfill any of your requests, for the proper completion of bureaucratic, legal, technical requirements, and for further activities required by law;

2. Methods: the data will be processed both on paper and using electronic/computer/telematic tools, in full compliance with the law, according to principles of lawfulness and fairness, and in a way that protects your confidentiality;

3. Optional provision: providing data is optional and not mandatory;

4. Consequences of refusal: refusing to provide certain data for the above purposes may result in the inability to manage the report effectively, provide you with appropriate feedback, or fulfill any of your requests;

5. Subjects or categories of subjects (recipients) to whom the data may be communicated or disclosed: the data resulting from the report will be sent to the company Winger S.r.l. based in Reggio Emilia, via Piccard 16/G, which acts as an external Data Processor pursuant to Article 28 of European Regulation 2016/679, and will be communicated to company employees specifically authorized by our company. The data may then be communicated to third parties only to fulfill legal obligations and in accordance with the procedures established by Legislative Decree 24/2023. The data will not be disclosed in any case;

6. Authorized persons for processing: the data will be processed exclusively by a very limited number of specially authorized employees;

7. Automated decision-making processes (e.g., profiling): no automated decision-making processes are managed in any way; R

8. ights of the data subject: you have all the rights provided by European Regulation 2016/679, such as the right to request access to personal data and their rectification, erasure, restriction of processing, the right to object to their processing, as well as the right to data portability. You also have the right to lodge a complaint with the Supervisory Authority;

9. Transfers to third countries: data is not transferred to third countries;

10. Data retention period: the data will be retained for the period strictly necessary to manage the reports and in compliance with Legislative Decree 24/2023 and current regulations;

11. Data Controller: the data controller is the undersigned company Baldinini S.r.l., with registered office in San Mauro Pascoli (FC), Via Rio Salto 1°, represented by its legal representative pro tempore. This information may be supplemented, orally or in writing, with additional elements and indications to better meet any of your informational needs regarding "Privacy" matters and to comply with regulatory developments.

24/10/2023 Baldinini S.r.l.