Whistleblowing

There is no exhaustive list of offences or conduct that may be the subject of a report. However, improper actions are considered relevant if they concern conduct, risks, offences or irregularities that have been committed or attempted and that are detrimental to the public interest.

Specifically, the report may concern actions or omissions that have been committed or attempted and that are:

• Criminal
• In violation of the Codes of Conduct or other company provisions that are subject to disciplinary sanctions
• Likely to cause pecuniary damage to the relevant administration or to another public body
• Likely to harm the image of STUDIO TRE SB SPA a Socio Unico
• Likely to cause harm to the health or safety of employees, users or the public or damage the environment
• Likely to harm users or employees or other persons on the company’s premises

Reports can be made using the “Whistleblower Reporting Form” duly completed and submitted to the Reporting Officer, Lisa Carri, using the following channels:

With the exception of cases where liability for libel and slander can be established in accordance with the provisions of the Italian Criminal Code or Article 2043 of the Italian Civil Code, and cases where anonymity is not enforceable by law (e.g. criminal, tax or administrative investigations, inspections by supervisory bodies), the identity of the whistleblower is protected in all contexts subsequent to the submission of the report.

Therefore, without prejudice to the exceptions mentioned above, the identity of the whistleblower will not be disclosed without their express consent, and all those who receive or are involved in the handling of the reports are required to protect the confidentiality of such information.

The breach of the duty of confidentiality is a cause for disciplinary liability, without prejudice to other forms of liability envisaged by law.

The whistleblower’s report is also exempt from the right of access envisaged in Article 22 et seq. of Italian Law 241/1990 as amended.

The document cannot therefore be viewed or copied by those requesting it, since it falls within the scope of the cases of exclusion under Article 24(1)(a) of Italian Law no. 241/90 as amended.

Note also that if the report is received electronically, STUDIO TRE SB Spa a Socio Unico will inform the whistleblower:

• That the report has been received.
• Of the possibility of being contacted again for more information needed for the investigation.
• Of the possibility of expanding on or updating the facts of the initial report if further information comes to light.

Monitoring of the functionality of the aforementioned communication channels is ensured by the Compliance Function, with the help of:

• The IT Manager, for dedicated emails and internet communication channels
• General Services, for ordinary mail

The Head of the Compliance Function ensures the mutual exchange of information and reports according to their respective purviews.

It is also possible to submit a report using the external channel offered by ANAC (Italian National Anti-Corruption Authority) if certain specific conditions exist.

For more information, see https://whistleblowing.anticorruzione.it/#/

Note that disciplinary action shall be taken in the event of false, unfounded or defamatory reports made with malice or gross negligence, or if the reports are made with the sole purpose of harming the Company, the person reported or other persons concerned by the report. Furthermore, the Company may also take appropriate legal action.