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Sall – Justrite Italia

Whistleblowing Policy

While the term whistleblowing refers to the process through which those who come into contact with the company can confidentially report violations of the law, the term whistleblowers refers to the people who report.

In Italy, the subject of whistleblowing is regulated by Legislative Decree 10 March 2023, n. 24, by the ANAC guidelines and by the Confindustria Operational Guide.

In the private sector, the whistleblowing regulation applies to companies that have employed, in the last year, an average of 50 subordinate workers, that have adopted an organization, management and control model or that deal with services, products, financial markets, prevention of money laundering, prevention of terrorist financing, transport safety and environmental protection.

Intending to operate in full compliance with current laws and regulations, Justrite Italia Srl encourages all its stakeholders to promptly report any behavior, commission/omission, that indicates/may indicate a violation of the law.

On this basis, Justrite Italia Srl has adopted an IT platform for receiving and managing whistleblowing reports, accessible at https://scswhistleblowing.com/justriteitalia/form , designed to guarantee the confidentiality of the reporting persons, the reports and the related documentation through End-to-End (E2E) encryption.

This platform, developed in compliance with the provisions of Legislative Decree no. 24 of 10 March 2023, Regulation (EU) 2016/679 and Legislative Decree no. 196 of 30 June 2003, will allow the reporting person to formalise the whistleblowing report in writing, via voice messaging system, or in a direct meeting with the manager identified by the Organizational Act approved by the administrative body and the latter to correctly take care of all legal obligations, providing timely feedback regarding the whistleblowing report.

Please note that, in the event that the manager identified by the Organizational Act approved by the administrative body is the same as the reporting person/reported person, the whistleblowing report may be addressed to the head of the company's Human Resources department, by registered mail with acknowledgement of receipt, to Justrite Italia Srl – For the attention of the head of the company's Human Resources department – ​​Via dei Prati Vecchi n. 37 – 42025 Corte Tegge (RE).

Furthermore, it is recalled that the reporting person acting in good faith is legally recognized as having confidentiality, protection against possible retaliation, and significant limitations of liability.

Finally, it is recalled that the reporting person is legally recognized as having the right to formalize the whistleblowing report by addressing it directly to the ANAC and that this right may be exercised if the manager identified by the Organizational Act approved by the administrative body has not diligently followed up on the whistleblowing report , or if there are reasonable grounds to believe that failure to diligently follow up on the report may result in retaliation.

(Whistleblowing – Organizational Act)

https://scswhistleblowing.com/justriteitalia/form
(IT platform)