Our policy: Speak out

At Mazzetti d’Altavilla we hope to maintain effective and accurate communication at all levels of the organization.

If anyone who works with us becomes aware of something they believe is inappropriate, dishonest, illegal, or dangerous, we would like them to raise their concerns directly with us.

We understand that some people may feel unsafe in speaking out; therefore, it will be our responsibility to ensure that they are protected from potential negative consequences of expressing their opinion.

We advise our managers on how best to address these issues discreetly and appropriately, but failing that, we have an anonymous external mechanism for open discussion.

By raising concerns, people enable us to respond appropriately and create a better workplace for everyone.

Responsibility for overseeing this policy lies with company management.

Mazzetti d’Altavilla encourages a culture of openness in all its relationships with employees and stakeholders. Effective and honest communication is essential to effectively address incidents of inappropriate, dishonest, illegal, or dangerous behavior.

When you share your concerns with us, we will ensure they are addressed appropriately; as a result, you will help us safeguard the interests of our staff, the organization, and the wider community.

We encourage all Mazzetti d’Altavilla stakeholders (employees, officials, part-time, fixed-term, occasional, temporary, seconded, and volunteer workers, etc.) to speak out.

We also encourage Mazzetti d’Altavilla's stakeholders, such as customers, suppliers, agents, contractors, external consultants, third-party representatives, business partners, sponsors, etc., to speak openly.

If you honestly and honestly believe you have observed inappropriate, dishonest, illegal, or dangerous behavior, you can report your concern and rest assured that we will support you.

The purpose of the Speak Up program is to provide an appropriate mechanism for reporting, investigating, and addressing inappropriate behavior. Inappropriate behavior occurs when an individual or individuals associated with Mazzetti d’Altavilla have done, are doing, or will do in the future something improper, dishonest, illegal, or dangerous. This includes, but is not limited to:

• act illegally or unethically or in violation of operating rules;
• violate the safety, integrity, quality and regulatory compliance of products;
• commit fraud or acts of corruption;
• fail to comply with legal obligations;
• endanger the health or physical or moral integrity of an individual;
• cause damage to the environment;
• facilitate tax evasion;
• carry out acts in violation of human rights or modern slavery;
• unauthorized disclosure of confidential information or other data breaches;
• discriminate against an individual, participate in sexual or psychological harassment;
• commit serious irregularities regarding the following:
  • accounting or auditing;
  • banking and financial crimes;
  • infringement of intellectual property rights;
  • conflict of interest.

This is not intended to be an exhaustive list; therefore, if there are other issues that concern you or you think we should be aware of, we would appreciate it if you would be willing to discuss them openly.

We also wish to emphasize that the Speak Up procedures do not replace standard workplace grievance practices or other relevant policies. In particular, please do not use the procedures described in this document to raise concerns about your personal circumstances, such as your terms and conditions of employment.

Option 1: Inform your immediate supervisor

If you have any concerns, you should first feel comfortable raising them with your immediate supervisor, as this is the standard way to report a problem. You can mention the matter directly or, if you prefer, put it in writing.

Option 2: Talk to one of the alternative internal contacts

If you feel unable to raise the issue with someone in your direct line of management, or if you feel that your direct manager has not adequately addressed your concerns, bring the matter to the attention of the RLS.

An internal report is the best way to get information to the right people, who can take timely and effective action to resolve the problem or avoid risks to the public interest.

Option 3: Internet reporting service

If the nature of the problem is such that you can remain anonymous, or if you have followed the internal channels listed in Options 1 and 2 and still have doubts, you can access the internet service (see Appendix 1 at the bottom of this page).

We do not encourage anonymous reports, but the online service allows individuals to remain anonymous (if you wish to report anonymously, you must ensure you have provided sufficient details to investigate the matter). The Manager may respond to anonymous reports where insufficient information is provided (while still guaranteeing anonymity) using the methods specified in the next paragraph.

The same process always applies, regardless of the method you choose to express your concerns.

After you report your concern and if the report is accepted, appropriate preliminary investigations will be carried out as quickly as possible, as well as an initial assessment of how best to proceed.

If you have raised your concerns with an individual within the company, you will be contacted by that individual or another appropriate individual who will assist you in assessing your concerns.

If you reported the problem online, you will receive a unique username that will allow you to communicate with the Manager, ensuring your anonymity. By revisiting the report submitted online and entering your unique username, you will be able to receive confirmation of your report within 7 days of submission, any requests for further information, and any updates on the status of your report.

The initial assessment may lead to a formal investigation, which, depending on the findings, will determine the actions to be taken and the expected timeline. You will receive information about your report. Where possible, you will be informed of the outcome of any investigations and assessments, as well as any actions taken (subject to confidentiality requirements).

If your concern more appropriately falls into other areas (e.g., disciplinary or workplace grievances), the person you contacted will let you know.

If you are dissatisfied with the response you receive, please remember that you can contact any of the other people listed as contacts in this policy. Mazzetti d’Altavilla is committed to ensuring that such concerns are handled fairly and correctly.

We do not tolerate victimization of anyone who raises a concern: we will ensure that you are supported and protected from negative repercussions, retaliation, or harm.

It doesn't matter if you were wrong, as long as you are reasonably convinced that something inappropriate has happened in the past, is still happening, or is likely to happen in the future.

Unless otherwise communicated, after you raise your concern, the person to whom the disclosure was made will serve as your point of contact regarding the matter. If you believe that raising your concern may result in harm to you or your career, you should immediately notify your contact or one of the other contacts listed in the "Alternative Contacts" section.

It is a disciplinary offense to threaten, treat in a detrimental manner, or take revenge on those who express their opinion in any way; furthermore, Legislative Decree 24 of March 10, 2023, protects all whistleblowers.

But it is also a disciplinary offence to raise an accusation maliciously or dishonestly.

Any personal data identifying you or another individual obtained in connection with any concern raised hereunder will be used only for the purposes described in this policy and in accordance with applicable data protection laws. Please see the privacy policy in Appendix 2 for more information on how Mazzetti d’Altavilla handles personal data.

Where required, this policy has been agreed/implemented after consultation with Mazzetti d’Altavilla management and the privacy consultancy firm.

Unless otherwise required by law, this policy may be modified at any time.

Speaking Openly Responsibles
The details of the local responsibles are as follows:

• CFO / HR Director: Chiara Belvedere
• General Manager: Silvia Belvedere
• Production Director: John Piano

Web address for reporting
: https://wb-hs.mc3-innovation.it/ARXivarNextWebPortal

Access ID to the
reporting

Password (which is changed upon second login)
segnalazioniare_mazzettiama

Phone number
[number to be inserted]

For the purposes of European data protection legislation, Mazzetti d’Altavilla is the data controller of personal data collected in writing, orally, or through the online platform.

We use personal data submitted under our Speak Up Policy only for the purpose of investigating allegations of inappropriate, improper, dishonest, illegal, or dangerous behavior ("inappropriate behavior") in accordance with our Speak Up Policy and in accordance with applicable laws. This document informs you of the information we collect when you report inappropriate behavior and how such personal data is used and shared within the Mazzetti d’AltavillaGroup.

What personal data do we process?

If you report a problem via the online service, we collect any personal data you include in your report, whether about you or anyone you may have identified in your communication. We do not ask you to leave your name, but we encourage you to periodically return to the online platform using your unique username, as concerns raised anonymously tend to be much less effective. Furthermore, if we do not have sufficient information, we may not be able to conduct a complete investigation.

If we receive a report that you have contacted your line manager or another group employee, we record the same information.

However you report it, we encourage you to include only relevant details that will help us investigate. You may be asked to provide certain types of personal information that fall into special categories, sometimes called "sensitive personal data." This definition includes information relating to particular matters such as racial or ethnic origin, religious beliefs, physical or mental health, trade union membership, sexual orientation, genetic data, criminal records, and criminal offences or proceedings.

If you are the subject of, or have been named in, a report, we will make every effort to notify you promptly, unless doing so would prejudice the investigation or we are prohibited by law.

How do we use this data?

A transcript is created of all verbal reports.

We use the data you submit to us to review the report and, if necessary, investigate the allegations made.

Where your relationship includes special categories of information and/or personal data relating to criminal offences or proceedings, we generally need to use this data for our legitimate interests (as set out above) and: [incomplete text in original – to be completed]

Data sharing

Reports submitted online will be reviewed by attorney Virginio Tagliabue of the PTBM law firm in Abbiategrasso (MI) and then forwarded to the appropriate parties.

How long will the data be kept?

Report transcripts are retained within the internet system for the entire period of time necessary to investigate the matter and, after a case is closed, for a further period of one year. Afterwards, all identifying information is deleted and, for internal reporting purposes, only a statistical record of the type of report, location, and outcome of the investigation is retained.

Where is the data stored and transferred?

The reports submitted are archived on cloud servers located in Italy.

Your rights

You can ask us at any time to provide you with a copy of your personal data, and if you believe the personal data we hold about you is inaccurate or incomplete, you will have the opportunity to correct or complete it. In some circumstances, you also have the right to object to our use of your data, as well as to ask us to delete it or limit its use. However, there are some exceptions to these rights. For example, we will not be able to delete your data if we are legally required to retain it or if we need to use it to establish or defend legal claims.