Introduction to Whistleblowing

Mollificio Valli S.r.l. favors an open corporate culture, based on ethics, transparency and responsibility, and inspired by corporate values: for this reason it asks the people who are part of it, such as administrators, managers, supervisory bodies, managers, employees and other collaborators and all its partners, to operate in full compliance with the Laws and Regulations, Code of Ethics and Human Rights.

The Company strongly encourages its stakeholders to report (so-called whistleblowing) any incorrect, dishonest or illegal activity – potential, highly probable or already committed – as well as behaviors that may cause damage or prejudice, including to the image, of Mollificio Valli S.r.l. To this end, the Company has implemented specific rules and a management process in compliance with the “Whistleblowing” legislation Legislative Decree. 24/2023 to provide potential whistleblowers with safe channels that guarantee the confidentiality of their identity and the information contained in the report and their protection from possible retaliation. Reports concerning the personal interests of the reporter, claims or grievances of a personal or commercial nature, claims or requests that fall within the discipline of the employment relationship are excluded from the scope of application of the legislation. In the event of unfounded reports, made in bad faith or with gross negligence, Mollificio Valli S.r.l. reserves the right to act to defend its interests and to protect injured parties.

Management of reports

Mollificio Valli S.r.l. has appointed a Committee of external experts in whistleblowing legislation, organizational models pursuant to Legislative Decree 231/01 and management systems, Union law and industrial relations and labor law, with characteristics of autonomy, impartiality, for the management of whistleblowing reports and independence with respect to processes that may be the subject of reports. The Company encourages whistleblowers to favor identified and non-anonymous reports, in order to streamline and make investigations more effective, although anonymous reports are also equally accepted, provided they are timely, detailed and supported by documentary evidence. In the case of anonymous reporting, the person managing the reports will, in fact, evaluate accordingly how it is appropriate to treat it. In order to guarantee the effectiveness of the reporting process and provide broad and indiscriminate access to all those who want to make a report, it has made available a plurality of alternative communication channels, such as:

· WRITTEN REPORT: registered mail with return receipt to be addressed to: Servizi Industriali Novara S.r.l.u c.a. WHISTLEBLOWING COMMITTEE – STRICTLY CONFIDENTIAL – at Confindustria Novara Vercelli Valsesia – Corso Cavallotti, 25 – 28100 – Novara. The report must be placed in two closed envelopes: the first with the reporting person’s identification data; the second with the report, in order to separate the reporting person’s identification data from the report. Both must then be inserted into a third closed envelope which bears the recipient indicated above on the outside.

· ORAL REPORTING: face-to-face meeting with the Committee following an appointment which can be requested by the whistleblower via e-mail with confirmation of receipt to the dedicated address [email protected] – the interview with the whistleblower, in this case, can also take place outside of company premises. It is possible to attach voice files, without textual content, to the dedicated e-mail address.

Monitoring the functionality of the aforementioned communication channels is guaranteed by the Whistleblowing Committee, which must be contacted in the event of any malfunctions.

Documentation

The Whistleblowing documentation of Mollificio Valli S.r.l. is available at the following links: