Whistleblowing

Armundia Group provides a channel for internal reporting in compliance with Legislative Decree No. 24 of March 10, 2023, concerning reports of violations that harm the public interest or the integrity of public administration or private entities, as identified in Articles 2, paragraph 1, letter a) and 3, paragraph 2 of the Decree.
The use of the internal channel is intended for the subjects indicated in Article 3 of the Decree: in particular, for subordinate and para-subordinate workers, self-employed workers and collaborators, freelancers, consultants, volunteers, and interns who perform their activities at the Company, as well as shareholders and individuals with administrative, management, control, supervision, or representation functions, even if such functions are exercised in a de facto manner. Additionally, to the extent that they have become aware of violations in the work context with the Company, it also includes employees of public administrations, independent administrative authorities, public economic entities, private law entities subject to public control, in-house companies, public law bodies, or public service concessionaires.
Reporting is also permitted if the aforementioned relationships have not commenced, provided that information about the violations was acquired during the selection process or in other pre-contractual phases; during the probationary period and after the termination of the legal relationship if information about the violations was acquired during the relationship itself.
Armundia Group has appointed the Company’s Supervisory Authority as the manager of its internal reporting channel, pursuant to Legislative Decree 231/2001 (hereinafter also referred to as “O.d.V.”).
 How to report?
Internal reports can be made through the following channels:
• Written channel: by sending a written report via registered mail to the Supervisory Authority at the following address: O.d.V. of Armundia Group S.r.l., C/O Studio Legale Rucellai & Raffaelli, Via Cesare Battisti n. 33, 40123 Bologna; in any case, the reporter is invited to place the report in two sealed envelopes: the first with their identifying information and the indication of the contact details for subsequent updates; the second with the subject of the report. Both envelopes must then be placed in a third sealed envelope, without the sender’s indication, which should bear the wording “Confidential for the Whistleblowing Manager” on the outside. The envelope may only be opened and managed by the Whistleblowing Manager, in compliance with the confidentiality obligations set forth by the Decree.
• Oral channel: by contacting the O.d.V. of Armundia Group S.r.l. at the number: 051-6440604 (Monday to Friday from 9:30 AM to 12:30 PM). Through the same phone number, the reporter may also request a direct meeting with the Reporting Manager. The meeting will be held in a location that ensures the confidentiality of the reporter. Oral reports (whether by phone or in person) will be documented in a record that will be signed by both parties. The reporter can verify, correct, and confirm the content of the record.
The report, which must be made in good faith, avoiding insulting or offensive tones, should indicate:
• name and surname, position, and role of the responsible person, if known;
• circumstances of time and place of the occurrence, along with any other elements deemed relevant for the report;
• any individuals present at the site of the violation who may potentially provide information about the incident;
• any attached documentation that may confirm the validity of the reported fact;
• any private interests related to the report;
• any other information that may facilitate the collection of evidence regarding the matter.
The report must also include the identity of the reporter and the contact details for follow-up by the Whistleblowing Office.
 How is the report managed?
Reports are received by the Company’s Supervisory Authority, which proceeds with the relevant investigation in compliance with the confidentiality obligations set forth by the Decree.
Within 7 days of receipt, the O.d.V. will acknowledge receipt of the report and will provide feedback on the outcome within the following 3 months.

Confidentiality and protections
In accordance with the Decree, the right to confidentiality of the reporter, the facilitator, and the individuals involved in the report is guaranteed.
Any form of retaliation against the reporter is prohibited, who may benefit from the protective measures provided for in Articles 16 and following of the Decree, if the conditions are met.
The reporter who believes they have suffered retaliation due to the report may notify the National Anti-Corruption Authority (ANAC) through its institutional channels.
Any processing of personal data is carried out in compliance with data protection regulations.

External reporting
The reporter may make an external report through the channel established and accessible on the ANAC website in the following cases:
• the internal reporting channel indicated in the Procedure is not active;
• the reporter has already made a report to the channel indicated in the Procedure and it has not been followed up;
• the reporter has reasonable grounds to believe that if they were to make an internal report through the channel provided by this Procedure, it would not be followed up or that the report could lead to the risk of retaliation;
• the reporter has reasonable grounds to believe that the violation to be reported could pose an imminent or obvious danger to the public interest.
For the use of the external reporting channel or for resorting to public disclosure, in the cases provided for by the Decree, please refer to the guidelines and the official ANAC website.
For more information on the procedure for managing internal reports and information on external reports, you can use this Whistleblowing policy.