WHISTLEBLOWING – REPORTING PATHWAY

In compliance with the relevant legislation (Legislative Decree 24/2023), the Company adopts a whistleblowing system through which it is possible to report any detected wrongdoings during the work activities to the designated corporate bodies in a confidential and protected manner.

The main useful information regarding the methods and channels of reporting, as well as the management of such reports, is provided below.

THE REPORTS

Reports consist of written or oral communications of information about violations. Violations consist of behaviors, acts or omissions that harm the public interest or the integrity of the Company, and that can be traced to:

  • illegal conduct relevant to legislative decree 231/2001 or violations of the 231 Organizational Models and Code of Ethics;
  • offenses concerning the application of the European Union or national acts established in the annex to Legislative Decree 24/2023 or national acts that implement the European Union acts established in the annex to Directive (EU) 2019/1937, although not indicated in the annex to the Decree. These offenses are related to the following sectors: public procurement; financial services, products, and markets and prevention of money laundering and terrorist financing; product safety and compliance; transportation safety; environmental protection; radiation and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; privacy and data protection and network and information system security;
  • actions that harm the financial interests of the European Union;
  • actions concerning the internal market, which compromise the free movement of goods, persons, services and capital;
  • acts or omissions that undermine the object or purpose of the provisions of the European Union in the areas mentioned in the above points.

When the reporter is unwilling to disclose his or her identity, reports are accepted even anonymously, provided they are detailed and adequately documented.

METHOD OF SUBMISSION AND RECIPIENTS OF THE REPORT

Reports may be made through the following reporting channels:

  • in written form: using the online Whistleblowing Platform made available by the Company, which provides a guided path for the whistleblower; the Whistleblowing Platform can be reached at the following web address: https://whistleblowing.mapei.com
  • in oral form: through voice messaging system connected to a specifically created telephone line that can be reached at 02-37673443. The number in question is common to all Italian Companies of the Mapei Group, so the reporter must indicate the specific Company involved in the report;
  • in oral form: through direct meeting with the team assigned to handle the reports.

The described channels ensure the confidentiality of the identity of the reporter, the person involved and the person mentioned in the report, as well as the content of the report and its communication through the use of encryption tools

Access to the Whistleblowing Platform is subject to the “no-log” policy to prevent the identification of the whistleblower who wants to remain anonymous: this means that corporate computer systems are unable to identify the access point to the platform (IP address) even if the access was from a computer connected to the corporate network. For each report entered, the Platform assigns a unique identification code that allows each reporter to check its status, completely anonymously. Equally, if a report is found to be inadequately substantiated, the manager of the reporting channel reserves the right to request further details from the reporter, making use of the Platform and again through this code, for the purpose of a thorough analysis of the reported matter.

Reports made through the mentioned channels are received and managed directly by a dedicated and specifically trained Team (so-called Whistleblowing Team), composed of i) Head of the Corporate Internal Audit Function, ii) Head of the Legal & Corporate Affairs Function; iii) Head of the HR & Organization Function Italy (Mapei S.p.A.).

The reporting person may also make an external report, through the channels activated by the National Anticorruption Authority (ANAC) and/or a public disclosure (e.g., through the press or social media), benefiting from the protection provided for internal/external reports if, at the time of its submission or public disclosure (as the case may be), one of the conditions set forth in Legislative Decree no. 24/2023 is met.

WHISTLEBLOWER PROTECTION AND RESPONSIBILITY

The Company ensures protection from any form of retaliation, for reasons related directly or indirectly to the report, against whistleblowers who make reports in good faith and all persons concerned and/or involved in the report (e.g.: facilitators, colleagues or relatives of whistleblowers, persons with knowledge of the facts being reported, etc.).

The identity of the reporting person and any other information from which the identity can be directly or indirectly derived may not be disclosed without the express consent of the reporting person, to persons other than those responsible for receiving or following up reports, expressly authorized to process such data, and subject to legal obligations.

Penalties are provided for those who violate the whistleblower protection measures.

Safeguards are not guaranteed and penalties are provided where possible, in the case of reports made with malice or gross negligence that turn out to be false and unfounded, with defamatory content or otherwise made for the sole purpose of harming the Company, the reported person or individuals concerned/influenced by the report. The Company reserves the right to take appropriate action, including legal action.

PROTECTION OF THE REPORTED

During the activity of verifying the possible violations, the individuals who are the subject of the reports may be involved in or notified of this activity but, in no case, will a proceeding be initiated only because of the report, in the absence of concrete findings regarding the content of the report. This could possibly be done because of other evidence found and ascertained from the report itself.

PRIVACY

To guarantee the right to protection of personal data to reporting persons, the acquisition and handling of reports takes place in accordance with data protection regulations. Any exchange and transmission of information involving the processing of personal data also takes place in accordance with Regulation (EU) 2018/1725. The protection of personal data is ensured not only for the reporting person but also for other persons to whom confidentiality protection applies, such as the person involved, the facilitator, the person mentioned in the report as they are affected by the data processing.