The management of misconduct reports

The management of misconduct reports

Whistleblowing is the spontaneous disclosure by an individual, called a “whistleblower” of an offense or irregularity detected within his / her professional environment, of which the whistleblower became aware in the performance of his / her work activities. The reporter is often an employee but can also be a third party, for example a supplier or a customer.

The reporting

The report is a confidential communication made by the whistleblower relating to a potential violation of the aforementioned provisions and must be detailed, based on precise and consistent factual elements, and have a degree of completeness as broad as possible to facilitate the checks and assessments to be carried out by the recipients of the same.

Whistleblowers

For Itema Group, anyone with an interest can make a report to the Parent Company. In particular, the following were identified as possible whistleblowers:

• the recipient of the Itema Group Code of Ethics
• the worker, trainee, former employee, volunteer, shareholder and director of Itema Group
• the employee of contractors, subcontractors and suppliers of Itema Group
• the candidate for a job position in Itema Group
• the recipient of the Organizational Model 231 of Lamiflex and the Parent company Itema S.p.A., including third parties to the organization who have become aware of offenses

Recipients

The recipient of the report is the subject or group of subjects authorized and responsible for receiving, sorting, ascertaining the reports, as well as communicating with the whistleblower. For the management of reports, Itema Group has provided two channels:

• the direct channel constituted by the Whistleblowing Committee
• an alternative channel independent from the Committee

The Itema platform

To allow all subjects the possibility of making a report, Itema Group has adopted a digital communication channel through which it is possible to inform about the alleged commission of irregular conduct, committed by persons belonging to or connected to the Group companies.

The digital platform made available by Itema Group is available at this link.

Please note that this communication channel, from the receipt of the report and in each subsequent phase, guarantees the confidentiality of the identity of the whistleblower in the management of the report and, if chosen by the whistleblower, his anonymity.

However, it is expressly forbidden by law to carry out acts of retaliation or discrimination, direct or indirect, against the whistleblower for reasons connected, directly or indirectly, to the report. In the case of employees, retaliatory or discriminatory dismissal or change of duties of the reporting subject are void by law.