WHISTLEBLOWING

In order to prevent and combat crimes and irregularities and in line with the values of transparency, correctness, honesty and legality that have always characterized their work, the companies of the Snaitech Group - including the Sole Shareholder of Snaitech, Pluto (ITALIA) S.p.A. - have activated an IT Channel for reporting violations of the relevant European and national legislation as well as the Organizational Model, the Anti-Corruption Policy of the Snaitech Group and the procedural system in force in each company as better described in the Whistleblowing Policies.

The IT Channel guarantees confidentiality and the anonymity of the Reporter.

The IT Channel does not use any type of tracking technology, such as cookies, as well as not recording identifying elements of the access stations (IP Address, User Agent, Language, etc.). In this way, the complete anonymity of the reporter is guaranteed if he decides not to reveal his personal details. When a report is made, the contents and/or data provided by the Reporter are encrypted and made available only to the members of the Whistleblowing Committee.

Comunica Whistleblowing

Comunica Whistleblowing is the Snaitech group IT channel that you can use to report violations of procedures or irregularities of which you are aware, guaranteeing maximum privacy and confidentiality.

For correct sending of reports and functional use of the application, we invite you to consult the "Whistleblowing Policy" and the FAQ section (where you can acquire further information) relating to the Group Company for which you wish to make the report.

Important: in as a consequence of the aforementioned safeguards to protect the confidentiality of the information sent, the Reporter must keep the unique code provided by the IT Channel once the report has been sent; this code will allow access to the report already transmitted for the possible insertion of further documentation/interlocutions or to obtain feedback from the Whistleblowing Committee.

Anonymous reports will only be taken into consideration if adequately detailed and provided they are made responsibly and in good faith.

Employees are reminded to access the IT Channel through a NON-company network

REFERENCE REGULATION

• Penal Code.
• Legislative Decree 10 March 2023, n. 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 concerning the protection of persons reporting breaches of regulatory provisions national.
• Guidelines on the protection of people who report violations of Union law and protection of people who report violations of national regulatory provisions - procedures for the presentation and management of external reports approved by ANAC with Resolution no. 311 of 12 July 2023.
• Legislative Decree 231/2001 and subsequent amendments.
• EU Regulation 2016/679 - General Data Protection Regulation (or GDPR, General Data Protection Regulation) and Legislative Decree 196/03 amended by Legislative Decree 101 of 2018 and any subsequent amendments.