Whistleblowing

Prestige Italia S.p.A. (hereinafter, “Prestige Italia” or the “Company”) is committed to operating in an ethical and responsible manner, and requires those in its organization (directors, executives, managers, employees and other associates) and its business partners to act accordingly.

Therefore, also in order to protect its values, Prestige Italia supports and encourages reports of potential violations of national and European regulatory provisions of which there is certain knowledge or reasonable suspicion, provided that the report is based on precise and concordant factual elements. Everyone is invited to promptly report illicit conduct and irregularities, or any acts and omissions aimed at concealing them, in order to allow them to be stopped in time and action to be taken against their authors. Inadequate handling of reports may result in the risk of legal action or sanctions for Prestige Italia, as well as negative impacts on its image and reputation.

To this end, Prestige Italia has implemented specific rules and a whistleblowing procedure for the handling of reports of wrongdoing (“Whistleblowing Policy” or “Policy”) to provide whistleblowers with secure channels that guarantee the confidentiality of their identity as well as of the information contained in the report and their protection against any retaliation. The full Policy is available at www.prestigeitalia.com.

WHO CAN MAKE A REPORT?

Whistleblowers may be the following individuals who work for the Company:

The Company’s employees, even if they hold a part-time or fixed-term employment relationship, apprenticeship, or if they perform occasional activities for the Company;
The self-employed (including agents and sales representatives);
Workers or collaborators of entities that provide goods or services or perform works for the Company;
Freelancers and consultants;
Trainees and interns, even if unpaid;
Shareholders and persons with administrative, management, control, supervisory or representative functions, even if exercised de facto;

even when the legal relationship has not yet begun, if information on breaches was acquired during the selection process or during other pre-contractual stages, or during the probationary period, or after the end of the legal relationship, if such information was acquired during the course of the relationship.

WHAT CAN BE REPORTED?

Prestige Italia strongly encourages its stakeholders to report any violation of Italian and/or European Union regulations, even if not yet committed, of which they have become aware in the context of their work and referring to one or more of the following matters:

Violations of provisions within the scope of European Union or national acts with respect to the following areas:

(i) public procurement;

(ii) financial services, products and markets and prevention of money laundering and terrorist financing;

(iii) product safety and compliance;

(iv) transport security;

(v) protection of environment;

(vi) radiation protection and nuclear safety;

(vii) food and feed safety, animal health and welfare;

(viii) public health;

(ix) consumer protection;

(x) protection of privacy and personal data and security of network and information system security

Breaches affecting the financial interests of the European Union referred to in Article 325 Treaty on the Functioning of the European Union (TFEU) and further specified in relevant European Union measures;

Breaches of provisions concerning the internal market, as referred to in Article 26(2) Treaty on the Functioning of the European Union (TFEU), including violations of the European Union’s competition and State aid rules, as well as violations concerning the internal market related to acts that violate corporate tax rules or mechanisms whose purpose is to obtain a tax advantage that frustrates the object or purpose of the applicable corporate tax law.

WHAT SHOULD NOT BE REPORTED?

The following will not be dealt with:

disputes, claims or demands related to an interest of a personal nature of the whistleblower that pertain exclusively to his or her individual working relationships or collaboration, or inherent in his or her working relationships with figures hierarchically subordinate to the whistleblower;
reports of violations already mandatorily regulated by Italian or European Union regulations on financial services, products and markets, prevention of money laundering and terrorist financing, and transportation security;
reports of national security breaches, as well as procurement related to defense or national security aspects, unless such aspects are covered by relevant secondary legislation of the European Union;
news that is patently unsubstantiated, information that is already totally in the public domain, as well as information acquired only on the basis of poorly reliable indiscretions or gossip (rumors).

WHAT SHOULD BE SPECIFIED IN THE REPORT?

The report must:

be made in good faith;
be circumstantiated and based on precise and concordant facts;
pertain to facts that can be ascertained and known directly to the whistleblower;
contain, if known, all information necessary to identify the person(s) held responsible for the breach.

HOW CAN A WHISTLEBLOWING REPORT BE MADE?

INTERNAL CHANNELS

The Company has provided internal channels that guarantee the confidentiality of the whistleblower, of the person reported and/or otherwise involved in the report, and of the content of the report. The management of internal channels is entrusted to a competent, autonomous, trained external party, specifically appointed by Prestige Italia (“Case Manager”).

IT CHANNEL

The whistleblower can submit a report through the IT platform “Whistle365” (“Platform”), which is provided by a specialized external service provider and can be accessed through a link from www.prestigeitalia.com.

The Platform allows the submission of written or oral reports, according to the instructions accessible from the link https://whistleprestige.prestigeitalia.com/.

WRITTEN REPORT BY PHYSICAL LETTER

The whistleblower may make a written report by registered mail with return receipt.

For this purpose, the report should be placed in two sealed envelopes, including, in the first, the identifying data of the reporter and, in the second, the subject of the report. Both envelopes should then be placed in a third envelope addressed to:

Prestige Italia S.p.A. c/o Ms. Monica Zanni, Attorney

Villa Loschi Zileri – Via Battaglione Val Chiese, 10

36100 Vicenza (VI)

Italy

RESTRICTED to the Case Manager of the whistleblowing reporting channel.

FACE-TO-FACE MEETING

The whistleblower can request a face-to-face meeting via the Platform or the written report. The Case Manager will give feedback by informing the reporter regarding the place and manner of the requested face-to-face meeting.

CAN A REPORT BE MADE ANONYMOUSLY

Reports from which the identity of the whistleblower cannot be determined are considered anonymous.

Although anonymous whistleblowing reports are accepted, the Company encourages whistleblowers to submit reports bearing their names, in order to streamline investigations and make them more effective.

The Case Manager follows up on anonymous reports where they are adequately substantiated and rendered with full details, that is, they are able to bring out facts and situations by relating them to specific contexts.

WHAT DOES PRESTIGE ITALIA DO AFTER RECEIVING THE WHISTLEBLOWING REPORT?

The Case Manager proceeds by giving feedback to the whistleblower as follows:

Receipt of the whistleblowing report;
Investigation;
Closing of the report.

EXTERNAL CHANNEL

The external reporting channel is activated at the National Anticorruption Authority (ANAC) https://www.anticorruzione.it/.

The whistleblower may submit an external whistleblowing report only if, at the time of its submission:

the internal whistleblowing reporting channel is not active or does not comply with Italian Decree 24/2023;
he or she has already made an internal whistleblowing report in accordance with Italian Decree 24/2023 and it has not been followed up;
he or she has reasonable grounds to believe that, if they were to make an internal whistleblowing report, the report would not be effectively followed up or that the report itself could result in the risk of retaliation;
he or she has probable cause to believe that the violation may constitute an imminent or obvious danger to the public interest.

PUBLIC DISCLOUSURE

The whistleblower may make a public disclosure if:

The whistleblower has previously made an internal and external whistleblowing report, or has made an external report directly, and no response has been received within the specified time frame regarding the measures planned or taken to follow up on the reports;
The whistleblower has probable cause to believe that the violation may pose an imminent or obvious danger to the public interest;
The whistleblower has good reason to believe that the external report may carry the risk of retaliation or may not be effectively followed up because of the specific circumstances of the particular case, such as those in which evidence may be concealed or destroyed or where there is a well-founded fear that the recipient of the report may be colluding with or involved in the same violation.

REPORT TO THE JUDICIAL OR ACCOUNTING AUTHORITY

In any case, the whistleblower has the option of making a report to the Judicial or Accounting Authority in cases where European Union or national law requires that the matter be referred to the competent national authorities because, for example, the violation constitutes a crime.