GROUP WHISTLEBLOWING POLICY
(POLICY FOR REPORTING)
INTRODUCTION
Reports of breaches of the law – and in particular reports of Relevant Breaches pursuant to the Whistleblowing Decree and Foreign Whistleblowing Laws (as defined below in par. 4) – can help identify and address in a timely manner, through adequate countermeasures and prevention, critical issues and risks to which all organisations are potentially exposed, including the companies of the Laminazione Sottile Group (hereinafter also “LS Group”).
Through the establishment and invitation to the conscious use of internal reporting channels, LS Group Companies aim to prevent and counter illegal conduct or conduct contrary to the principles and rules prescribed in their organisational models, codes of ethics, company policies and procedures, protecting the confidentiality of whistleblowers and other protected persons, safeguarding them from the risks of any retaliation, in full compliance with all applicable laws.
1. PURPOSE
The purpose of this Policy is to establish the rules and procedures by which to report breaches and/or unlawful or illegitimate conduct/behaviour (acts or omissions) in compliance with the provisions of Italian Legislative Decree 24/2023 (hereinafter also “Whistleblowing Decree”) and applicable Foreign Whistleblowing Laws as well as to regulate the process of receiving, analysing and processing such reports concerning the companies of the Laminazione Sottile Group.
For matters not expressly provided for in this Policy, reference must be made, without exception, to Legislative Decree 24/2023 (and any subsequent amendments and supplements) as well as the relevant legislation applicable in the country of reference.
2. RECIPIENTS AND FIELD OF APPLICATION
This Policy applies to Laminazione Sottile S.p.A. and all its subsidiaries (part of the LS Group).
In particular, the Policy applies to all persons, “Whistleblowers”, who report Information relating to Breaches committed or which, on the basis of concrete elements, could be committed within Laminazione Sottile S.p.A. or the other LS Group Companies with which the Whistleblowers work, have worked, maintain or have maintained legal relationships or have come into contact within the scope of their professional or working activity (for example: employees, self-employed workers, freelancers and consultants, volunteers and trainees, shareholders, persons with administrative, management, control, supervisory or representative functions, workers or collaborators of contractual partners and suppliers of goods and services).
Subsidiaries are responsible for adopting this document and ensuring compliance with it.
In certain circumstances this Group Policy may differ from applicable local laws. In these cases, it is established that the rules that best protect the Whistleblower shall prevail and apply, whether they are contained in local legislation or in this document: where local laws provide for greater safeguards than those established in this Policy, local laws shall apply.
3. ISSUE, REVIEW MECHANISM AND TERMS OF VALIDITY
This Policy, which for the Italian companies of the LS Group is an integral part of the Organisation, Management and Control Model adopted pursuant to Legislative Decree 231/2001 (hereinafter “Model 231”), shall take effect from the date of its issue (indicated on the document).
Any subsequent update repeals and supersedes, from the date of its issue, all previously issued versions.
The Group Compliance Function is responsible for updating this Policy and disseminating it.
The Policy is subject to periodic review (at least five years) and is reissued by the Issuing Body where necessary (in particular in the event of organisational changes, any gaps/critical issues found or if the applicable national and international standards and regulations, referred to as best practices, are subject to change).
4. DEFINITIONS
The definitions relevant for the purposes of this Policy are the following:
• Whistleblowing Decree (issued in Italy): Legislative Decree of 10 March 2023, No. 24, “Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons reporting breaches of Union law and laying down provisions for the protection of persons reporting breaches of national regulatory provisions”
• Whistleblowing Directive: Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons reporting breaches of Union law, as defined therein
• Foreign Whistleblowing Laws: All the laws in force in the countries where the foreign companies of the LS Group (i.e. companies based in a country other than Italy) are based regarding Whistleblowing
• Reporting Person, “Whistleblower”: person who submits a report of breaches/unlawful conduct under this Policy
• Reported Person: person to whom one or more unlawful conduct is attributed (as defined below)
• Breach and/or unlawful conduct: any act or omission (occurring in the course of work activities or having an impact thereon) that involves a breach of the Code of Ethics, Model 231 or the policies/ procedures adopted by the Company, as well as regulations/laws (as defined in par. 7 of this Policy and the Whistleblowing Laws applicable in the country of reference)
• Report: any information relating to possible “breaches/ unlawful conduct” submitted by a Whistleblower to the functions designated to receive such reports
• Anonymous report: any report in which the identity of the Whistleblower is not disclosed, nor traceable
• Reporting made in “bad faith”: a report lacking any factual basis and made for the purposes of harming or prejudicing employees, internal collaborators, members of corporate bodies or third parties (e.g. customers, suppliers, partners, consultants, external collaborators) in a business relationship with the Companies of the LS Group
• Facilitator: a natural person who assists a Whistleblower in the reporting process, operating within the same working context and whose assistance must be kept confidential
• Reports Handler: Person/Function/Entity authorised by the corporate Board to receive and manage the reports covered by this Policy
• Work context: work or professional activities, present or past, carried out within the framework of the relationships referred to in Article 3, paragraphs 3 or 4 of Legislative Decree 24/2023, through which, regardless of the nature of such activities, a person acquires information on breaches and within which they may risk retaliation in the event of public reporting or disclosure or reporting to the judicial or accounting authority
GROUP WHISTLEBLOWING POLICY (POLICY FOR REPORTING)
• Involved Person: the natural or legal person mentioned in the report as the person to whom the breach is attributed or as the person in any case involved in the breach reported or publicly disclosed
• Retaliation: any behaviour, act or omission, even if only attempted or threatened, carried out as a result of the report, the report to the judicial or accounting authorities or public disclosure, which causes or may cause the Whistleblower or the person who made the report, directly or indirectly, unjust harm
• Follow-up: the action taken by the person entrusted with the management of the reporting channel to assess the existence of the reported facts, the outcome of the investigations and any measures taken in order, where appropriate, to remedy the reported breach
• Feedback: communication to the Whistleblower of information relating to the follow-up that is given or that is intended to be given to the report
• Model 231: Organisation, Management and Control Model adopted by Laminazione Sottile SpA and the Italian Subsidiaries pursuant to Legislative Decree no. 231 of 2001 (i.e., Decree 231)
• Supervisory Body: the Supervisory Body of Laminazione Sottile SpA and of the Italian Subsidiaries, referred to in Article 6 of Decree 231.
5. RESPONSIBILITIES AND DISCLOSURE
The governance bodies of the LS Group, supported by the Steering Committee and the Group Sustainability Committee, and with the involvement of the various Functions involved (including but not limited to the Compliance, Legal, Human Resources, Organisation & Communication Functions) play a strategic role in the full implementation of this Policy. In particular, in the management of reports, the following specific responsibilities are identified:
BOARD OF DIRECTORS
Appointment of the Reports Handler (as defined in par. 4)
Monitoring of the reports management system and the adoption of the consequent corrective actions and measures (where identified)
STEERING COMMITTEE
Establishment of appropriate internal reporting channels in accordance with applicable regulations
Monitoring of the adoption of appropriate remedial and/or improvement actions in relation to the reported breaches
Evaluation and initiation of any disciplinary sanctions and/or legal actions against Whistleblowers acting in bad faith, upon proposal by the competent Functions (HR Function and Legal Function respectively)
Receipt, analysis and feedback of reports
Proposal of remedial and/or improvement actions in relation to the reported breaches (to the competent corporate functions of the Group Company concerned by the report) and verification of their implementation
In order to ensure continuous improvement of its performance in relation to the processes covered by this Policy, the LS Group undertakes to identify the key performance indicators (KPIs), to set achievable improvement objectives and to periodically monitor and report the results achieved in the Annual Sustainability Report.
REPORTS HANDLER
6. RULES AND GENERAL PRINCIPLES OF CONDUCT
All Recipients, i.e. persons involved in any way in the reports referred to in this Policy, are required to observe the procedures set out herein, the existing legal provisions on the matter, with particular reference to current legislation on Privacy (Privacy Code, GDPR and all other laws in force regarding the protection of personal data), as well as the behavioural rules provided for in the Group Code of Ethics and Model 231 adopted by the Italian LS Group Companies. More specifically:
• It is the responsibility of the Whistleblower – including anonymous Whistleblowers – to submit reports in good faith and in line with the purposes stated in this Policy: reports that are manifestly unfounded, opportunistic and/or made for the sole purpose of damaging the Whistleblower or persons otherwise affected by the report shall be duly archived and may be subject to disciplinary sanctions and/or legal action;
• It is the responsibility of the persons authorised to manage reports, i.e., “Reports Handlers”) as well as of all Recipients of this Policy to ensure that the processing of personal data takes place in compliance with the LS Group Data Protection Policy and applicable laws;
• It is the responsibility of the Functions involved in the report management process to ensure the maintenance of the necessary conditions of independence and absence of conflict of interest, as well as due objectivity, competence and professional diligence, as established in international standards as well as in the LS Group Code of Ethics;
• It is the responsibility of anyone who receives a Report outside the official channels (for example in the event of receipt of a Report by a person not authorised by the LS Group to manage reports):
º to maintain the utmost confidentiality of the information, including the identity of the Whistleblower, the Reported Person and other persons mentioned;
º to advise the Whistleblower to use the official channels or forward the Report through such channels;
º to delete all information related to the Report after forwarding it and receiving confirmation of receipt from the Reports Handler;
º to refrain from any independent initiative for analysis or investigation of the Report.
• It is the responsibility of anyone who receives a Report of predicate offences or breaches falling within the scope of Legislative Decree 231/2001 issued in Italy to promptly inform the Supervisory Body (“SB” provided for by Decree 231).
7. SUBJECT MATTER OF REPORTS
“Whistleblowing” means any Report, submitted to protect the integrity of the LS Group Companies, concerning (by way of example and not limited to):
• breaches of the LS Group Code of Ethics;
• breaches of Model 231 (adopted by the Italian Group Companies);
• breaches of Group Policies and/or internal procedures;
• breaches, in the context of supply chain management, of the Code of Conduct for suppliers or of the Responsible Procurement Policy adopted by the LS Group;
• the commission, including attempted commission, of offences relevant pursuant to Italian Legislative Decree 231/01;
• a crime or offence (administrative, accounting, civil or criminal offences);
• unlawful acts falling within the scope of application of EU and/or local legislation relating to the sectors of public procurement, financial products and markets and the prevention of money laundering and terrorist financing; environmental protection; public health; protection of privacy and personal data and security of networks and information systems;
• breaches of the restrictive measures of the European Union (in accordance with the provisions of art. 7 of Legislative Decree 211/ 2025 issued in Italy which amended art. 1 of the Whistleblowing Decree);
• acts or omissions that harm the EU’s financial interests (Article 325 TFEU);
• acts or omissions concerning the free movement of goods, persons, services and capital in the internal market (including, but not limited to, breaches of EU competition law);
• acts or conduct undermining the object or purpose of the EU provisions in the areas indicated above;
• information relating to the conduct aimed at concealing the breaches indicated above;
• well-founded suspicions/unlawful activities that have not yet been carried out but that the Whistleblower reasonably believes may occur in the presence of concrete, precise and consistent elements.
It should be noted that the following types of communications/ reports do not fall within the scope of this Policy:
GROUP WHISTLEBLOWING POLICY (POLICY FOR REPORTING)
• complaints, claims or requests of a personal nature, which relate to individual employment relationships or relationships with hierarchically superior figures, colleagues or collaborators;
• reports of breaches already governed by special laws, already regulated by EU regulations or EU Directives already transposed;
• reports concerning security and defence, procurement in the defence and national security sector;
• reports relating to requests, complaints or grievances concerning possible disruptions related to activities of a commercial nature that do not involve breaches of European Union acts on consumer protection (e.g. claims for billing, etc.).
These reports must be forwarded to the company functions responsible for receiving them and will be handled in line with the relevant regulations
8. CHARACTERISTICS OF REPORTS
Reports must be based on precise and consistent factual elements, of which the whistleblowers have become aware due to the functions performed.
Report can also be sent anonymously without, therefore, the Whistleblower indicating their personal details.
In order to allow a faster and more effective management of the matters reported by the Whistleblower, the LS Group urges Whistleblowers to reveal their identity which shall be kept confidential in compliance with this Policy.
Reports, even if anonymous, must in any case be documented and substantiated, so as to provide the useful and appropriate elements to allow appropriate verification on the merits of the reported facts.
Except in the case of anonymous reports, they must possibly contain the following elements:
• personal details and position/role within the company of the Reporting Person at the time of the events;
• names and role of the persons who committed the offence and corporate role;
• name of additional parties involved in the offence and corporate role;
• the manner in which the facts were established or became known;
• a clear and complete description of the facts ascertained or of which the Reporting Person became aware, such as to allow their verification and ascertainment;
• circumstances of time and place (presumed or certain) in which the facts subject to the Report occurred.
In addition, for the purposes of the appropriate Follow-up, Reports should indicate, where available:
• the indication of any other persons who may formally report on the facts subject to the Report;
• documentary evidence that can confirm the merits of the reported facts;
• any other information that may provide objective evidence on the existence of the reported facts.
Attached to this Policy is a template containing all the information useful for the effective handling of the Report (see Annex 2).
Even in the case of a non-anonymous Report, the recipient is not allowed in any context or time after the Report to disclose to anyone the name of the Whistleblower, the duties currently and previously performed, nor any other information that may lead to the identification of the person, unless the latter explicitly authorises such disclosure by means of a specific signed declaration, possibly integrated with or attached to the report of the unlawful act. In the event of a Report submitted by email, such declaration must be produced after being sent and signed by the Whistleblower with a handwritten signature. Breach of this obligation of confidentiality constitutes a serious violation of the provisions of the Group Code of Ethics and Model 231 and as such is punishable, without prejudice to civil and criminal liability.
9. REPORTING CHANNELS
The LS Group provides clear information on the channel, procedures and conditions for making internal reports and external reports. The aforementioned information is displayed and made easily visible in the workplace, as well as accessible to persons who, although not attending the workplace, have a legal relationship with the Company (to this end, this Policy is published in a dedicated section of the corporate websites).
The LS Group has activated multiple internal Reporting channels entrusted to the management of Persons/ Entities endowed with autonomy and independence. Such Persons, as Reports Handlers shall, in compliance with the principles of impartiality, professional diligence and confidentiality, carry out any activity deemed appropriate for the management of the Report (in accordance with the provisions of the Whistleblowing Decree and foreign Whistleblowing Laws).
Reports may be sent, including anonymously, referring alternatively to one of the following internal channels (to the references indicated in Annex 1):
1 - Internal channel – Whistleblowing (SB)
The reports addressed to this channel are taken over and managed by the SB.
2 - Internal channel – Compliance
It is possible to contact the Group Compliance Function (internal function reporting directly to the corporate Board, with autonomy and independence).
GROUP WHISTLEBLOWING POLICY (POLICY FOR REPORTING)
In the event that the reported facts concern breaches of Model 231 and/or the Code of Ethics or in the event of well-founded suspicion of a criminal offence, the Compliance Function immediately forwards the Report to the SB (in compliance with the principles of confidentiality and protection of the Whistleblower).
Reports through internal channels may be made either in writing or orally. In the latter case, they may be carried out by arranging an appropriate appointment with the Reports Handler of the reporting channel (contactable as indicated in Annex 2).
It is understood that, whatever internal channel used, Reports shall be processed in compliance with the provisions contained in this Policy and the applicable legislation.
3 - Further provisions
It should be noted that the legislation provides that, where internal Reporting channels are not available and when certain conditions provided for by locally applicable laws and regulations are met, Whistleblowers may use the external Reporting channels made available by the competent Public Authorities, Bodies or Local Institutions. Such external channels are managed according to the procedures established by the aforementioned Authorities within their own regulations or guidelines (to which reference is made).
10. INTERNAL REPORT MANAGEMENT PROCESS
Whatever internal channel is chosen to make a Report, the Reports Handler directly carries out all the activities necessary for the analysis and management of the facts covered by the Report, according to the procedure described below.
10.1 PRELIMINARY INVESTIGATION
The first phase of the investigation is aimed at carrying out the necessary preliminary checks in order to assess the relevance, scope and potential risks deriving from the reported facts.
In particular, the Reports Handler applies their own Regulations and evaluates the Report by analysing the following elements:
• actual existence of the alleged breaches;
• actual relevance of the alleged breaches;
• completeness of the Report;
• level of detail in the description;
• temporal and logical consistency of the facts;
• arguments and documents to support the truthfulness of the reported facts;
• repetition of reports concerning the same persons involved and/or the same facts.
In the event that a Report is not adequately substantiated or one or more essential elements are missing, the Whistleblower shall have the right to request further details from the Whistleblower, where possible, for the purposes of an in-depth analysis of the reported case.
Whistleblowers are required to fully cooperate with the Reports Handler, promptly providing the requested information and documents and offering any additional support.
In the case of an anonymous Report, it is guaranteed that only the Reports Handler can trace the identity of the sender; this procedure can be implemented only in the event of an explicit request by a competent Authority where the Report gives rise to a complaint to the same Authorities or the judicial Authority or in the event of disciplinary proceedings. Violation of this provision constitutes a serious breach of the provisions of the Code of Ethics and Model 231 and as such is punishable, without prejudice to civil and criminal liability.
10.2 VERIFICATION
The objective of the verification activities is to carry out specific analyses and evaluations to ascertain the validity of the reported facts through appropriate internal investigations.
The Reports Handler examines the reports and decides whether or not to continue the investigation process.
They may directly interview the author of the Report – if known – or the persons mentioned therein.
At the end of the verification, the Reports Handler draws up a Report to be submitted to the Board of Directors.
10.3 EVALUATION AND FEEDBACK
At the end of the investigative/verification phase, the Report Handler provides feedback to the Whistleblower – if known – on the decisions taken.
In particular, they carry out the following activities:
• issues to the Whistleblower notice of receipt of the Report within seven days of the date of receipt;
• diligently follows up on the reports received;
• provide feedback on the Report within three months of the date of the notice of receipt or, in the absence of such notice, within three months of the expiry of the seven-day period from the submission of the Report.
GROUP WHISTLEBLOWING POLICY (POLICY FOR REPORTING)
The feedback consists of notifying the Whistleblower of the follow-up that is given or that is intended to be given to the Report, including the communication of the possible absence of grounds to proceed with the investigation and consequent archiving.
The Report Handler makes and motivates their decisions:
• where the investigations reveal situations of violations of the 231 Model and/or the Code of Ethics, or in the case of a well-founded suspicion of a criminal offence, the Report Handler promptly communicates the Report and their assessments to the Chairman, Chief Executive Officer, and, at the first possible meeting, to the Board of Directors and the Board of Statutory Auditors;
• if the Report is unfounded, the procedure shall be archived.
Reports submitted for the purpose of harming or otherwise prejudicing the Reported Person, as well as any other form of abuse of this document, entail responsibility of the Whistleblower, in disciplinary proceedings and other competent forums, particularly if the falsity of the Report or the instrumental and voluntary falsity of accusations, comments, or criticisms is established.
If, during the checks, the received Report is found to be unfounded and made with intent or gross negligence, the Company involved may apply appropriate disciplinary and sanctioning measures against the Whistleblower.
10.4 CORRECTIVE MEASURES
At the end of the investigations and once the Report has been managed, the Reports Handler defines and shares with the competent company Functions a corrective plan to be implemented, i.e. specific remedial and/or improvement actions in relation to the reported breaches, the persons responsible for implementing the plan, and the related completion timelines.
11. PROTECTIVE AND SAFEGUARDING MEASURES
Throughout the management of the Report, the right to confidentiality of the Whistleblower, the person involved and the person mentioned in the Report is guaranteed.
In order to ensure the reconstruction of the different phases of the process, the Reports Handler is required to document, through the storage of electronic and/or paper documents, the reports received, in order to ensure complete traceability of the actions undertaken in fulfilling their institutional duties.
Electronic documents are stored in a “directory” protected by authentication credentials known to the members of the SB/Compliance Function (depending on the reporting channel used) or by persons expressly authorised by the Reports Handler.
In the event of reports produced in evident bad faith, the Reports Handler reserves the right to archive them, deleting the names and elements that may allow the identification of the reported persons.
Paper documents are stored in a designated location whose access is allowed to the members of the SB/ Compliance Function (depending on the Reporting channel used) or to the persons expressly authorised by the Reports Handler.
In addition, the following principles apply:
• Reports may not be used for longer than is necessary to follow up on them appropriately;
• The whistle-blower’s identity and any other information that might be discovered about them, either directly or indirectly, may not be revealed without the Whistleblower’s express consent to anyone else other than the persons in charge of receiving or following up on Reports, who are expressly authorised to process such data pursuant to Articles 29 and 32, paragraph 4, of Regulation (EU) 2016/679 and Article 2-quaterdecies of the personal data protection act under Italian Legislative Decree No. 196 of 30 June 2003;
• During disciplinary proceedings, the Whistleblower’s identity may not be revealed, when a formal reprimand for the disciplinary complaint is based on additional separate investigations regarding the Report, even if resulting from it. If the formal reprimand is based, either wholly or in part, on the Report and knowledge of the Whistleblower’s identity, is essential for the defence of the accused, the Report may be used for the purposes of disciplinary proceedings solely with the Whistleblower’s express consent to reveal their identity;
• Internal and external Reports and the related documentation are kept for the time required to handle the Report and, in any case, not for longer than five years starting from the date when the final outcome of the reporting procedure is notified, in accordance with the obligations of confidentiality under Article 12 of Decree 24/2023 and the principle under Articles 5, paragraph 1, letter e), of Regulation (EU) 2016/679 and Article 3, paragraph 1, letter e), of Legislative Decree No. 51 of 2018;
• if the Report is submitted via a recorded telephone line or other recorded voice messaging system, the Report, with the consent of the Whistleblower, is documented by the personnel in charge of managing the Report through recording on a device suitable for storage and listening, or by full transcription. In case of transcription, the Whistleblower may verify, correct or confirm the content of the transcription by signing it;
• If a non-recorded phone line or another non-recorded voice-messaging system is used for submitting Reports, then the Report shall be documented in writing through a detailed account of the conversation by an authorised member of staff. The Whistleblower may verify, correct or confirm the contents of the transcription by signing the document;
GROUP WHISTLEBLOWING POLICY (POLICY FOR REPORTING)
• When, at the request of the Whistleblower, the Report is made orally during a meeting with the personnel in charge, it is, with the Whistleblower’s consent, documented by the personnel in charge through recording on a suitable device for storage and listening, or by minutes. In case of minutes, the Whistleblower may verify, correct and confirm the minutes of the meeting by signing the document;
• The Whistleblower may not suffer any retaliation (dismissal, suspension or equivalent measures and all the cases provided for in Article 17, paragraph 4 of the Whistleblowing Decree and by the local reference regulations constitute retaliation).
12. PROHIBITION OF RETALIATORY ACTS
The LS Group does not tolerate any form of retaliation against a person who has submitted a Report (whistleblowing) or who has been involved in the process of handling a Report.
An act of “retaliation” is any unjustified and/or harmful action against a Whistleblower, a facilitator, a witness or a person connected to a Whistleblower, in response to a Report.
Any Whistleblower or anyone who has provided information regarding the management of a Report (whistleblowing) who believes they are subject to retaliatory acts, including threats and attempted retaliation, may report it in the manner provided in this Policy.
Anyone who carries out a retaliatory act against a Whistleblower or person involved in the process of managing a Report shall be subject to measures according to the disciplinary and sanctioning system provided, in line with the Human Rights Policy and the Code of Ethics adopted by the LS Group and in compliance with the applicable regulations.
13. DISSEMINATION
The LS Group promotes the communication of this Policy, in a manner suitable for dissemination to all Recipients and the implementation of specific training programmes, in order to ensure effective knowledge by its personnel.
In order to ensure its dissemination to all interested third parties/external parties, this Policy is published in a dedicated section of the corporate websites.
ANNEX 1 – INTERNAL REPORTING CHANNELS
1 - Internal channel – Whistleblowing (SB)
• Certified email of Lawyer Gianluca Armillei (external person designated to receive Reports) and Chairman of the SB: avv.gianluca.armillei@legalmail.it
• Ordinary email of Lawyer Gianluca Armillei: gianluca.armillei@advisor231.it
• Email of the SB: odvls231-2001@laminazionesottile.com
• Ordinary mail address of the SB: Lawyer Gianluca Armillei, Largo Solera 7/10 - 00199 ROME
• Telephone number of Lawyer Gianluca Armillei: +39 338 6780223
2 - Internal channel – Compliance
• Email Group Compliance: compliance@laminazionesottile.com
• Telephone number: +39 348 2388279
• Box (mailbox dedicated to Reports/complaints) available at the Group Plants
ANNEX 2 – SAMPLE INFORMATION FOR REPORTS
NAME AND SURNAME OF WHISTLEBLOWER1:
JOB TITLE OR POSITION:
TEL/CELL:
DATE/PERIOD OF THE FACT (dd/mm/yyyy):
PLACE WHERE THE FACT OCCURRED:
E-MAIL:
DESCRIPTION OF THE FACT (CONDUCT AND EVENT):
AUTHOR(S) OF THE FACT:2
OTHER PERSONS AWARE OF THE FACT AND/OR ABLE TO REPORT ON THE SAME:3
ANY ATTACHMENTS IN SUPPORT OF THE REPORT:
1 To be indicated in case of non-anonymous reporting
2 Indicate personal data if known and, otherwise any other element suitable for identification
3 Indicate personal data if known and, otherwise any other element suitable for identification
ANNEX 3 - REFERENCES
• Laminazione Sottile Group Code of Ethics
• Group Data Protection Policy
• Group Human Rights Policy
• Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons reporting breaches of Union law (also known as the Whistleblowing Directive)
• Italy: Legislative Decree 10 March 2023, n. 24 (also known as Whistleblowing Decree), of “Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons reporting breaches of Union law and laying down provisions for the protection of persons reporting breaches of national regulatory provisions”
• UK: Public Interest Disclosure Act 1998 (PIDA)
• All Whistleblowing Laws where issued in countries where the Group operates
• GDPR – EU Regulation 679/2016 on the processing of personal data
GLOSSARY
Keywords Definition
Employees/personnel
Group companies
Group
Third Parties
REVISION
15 December 2025
All individuals linked to the Laminazione Sottile Group or to the Group Companies by an employment agreement (including consultants and secondees), as well as all members of the executive, strategic and supervisory bodies.
These are Group companies controlled directly or indirectly by Laminazione Sottile S.p.A.
The Laminazione Sottile Group, consisting of Laminazione Sottile S.p.A. and its subsidiaries.
Natural or legal persons linked to the Group by a contract such as, for example, customers, suppliers, agents, etc.