WHISTLEBLOWING POLICY

Of COIPA Italia S.p.A. & Group Ventura

Introduction

At Coipa Italia S.p.A. & Gruppo Ventura, we are committed to maintaining the highest standards of ethical conduct, transparency, and accountability in all our operations. We recognize that the success of our company depends not only on achieving our business goals but also on acting with integrity in all our dealings. This Whistleblowing Policy ensures that employees, contractors, and stakeholders are provided with a clear, confidential, and safe way to report concerns regarding illegal, unethical, or inappropriate behavior without fear of retaliation.

This policy outlines the procedures for reporting wrongdoing, the protections afforded to whistleblowers, and the mechanisms for investigating and addressing reported concerns.

1. Purpose of the Whistleblowing Policy

The primary purpose of this policy is to encourage employees, contractors, suppliers, and other stakeholders to report any concerns or suspicions of misconduct within the company. The aim is to:

• Detect, prevent, and address unethical or illegal activities.
• Safeguard the company’s reputation, integrity, and operational efficiency.
• Ensure compliance with laws, regulations, and company policies.
• Provide a safe and protected channel for individuals to report concerns.

2. What to Report

Whistleblowers are encouraged to report any actions, behaviors, or activities that may involve or lead to:

• Corruption, Bribery, or Fraud: Any form of bribery, corruption, kickbacks, or fraudulent activity.
• Violation of Laws or Regulations: Any illegal activity, including violations of labor laws, health and safety regulations, environmental laws, data protection laws (e.g., GDPR), etc.
• Conflict of Interest: Situations where personal interests conflict with professional duties, leading to compromised decision-making.
• Misuse of Company Assets: Any unauthorized or inappropriate use of company resources, intellectual property, or finances.
• Discrimination and Harassment: Any act of discrimination, harassment, or unfair treatment, including sexual harassment or intimidation.
• Health and Safety Violations: Any unsafe working conditions or failure to comply with health and safety standards.
• Environmental Violations: Actions that harm the environment or violate sustainability regulations.
• Violation of Company Policies: Any breach of the company’s internal codes of conduct, policies, and procedures.

3. Reporting Channels

Coipa Italia S.p.A. & Gruppo Ventura provides multiple confidential channels for whistleblowers to report their concerns:

• Internal Reporting System: Employees, contractors, and other stakeholders can use an internal secure and confidential reporting tool (email, hotline, or intranet) to report incidents.
• External Reporting Platform: An independent, third-party platform may also be available for individuals to report concerns anonymously and securely.
• Direct Contact: Whistleblowers may choose to contact their immediate supervisor or manager, the Compliance Officer, or the HR Department directly. However, this may not be suitable in cases where the supervisor or manager is involved in the misconduct.

4. Protection of Whistleblowers

Coipa Italia S.p.A. & Gruppo Ventura is committed to protecting whistleblowers against any form of retaliation, discrimination, or harassment. Whistleblowers who report concerns in good faith are entitled to the following protections:

• Confidentiality: All reports will be handled with the highest level of confidentiality. The identity of the whistleblower will be protected, and no information will be disclosed without their consent unless legally required.
• Protection from Retaliation: Retaliation, intimidation, or harassment against any employee or stakeholder who reports misconduct is strictly prohibited. This includes dismissal, demotion, harassment, or any form of discrimination as a consequence of whistleblowing.
• Anonymity: Whistleblowers have the option to report anonymously. While anonymity may limit the company’s ability to follow up or provide feedback, we will make every effort to investigate and address all reports.

5. Investigation Process

When a whistleblowing report is made, it will be taken seriously and handled with due diligence. The investigation process follows these steps:

• Acknowledgment: Once a report is received, the whistleblower will receive an acknowledgment, outlining the next steps in the investigation process.
• Assessment: The report will be assessed by the Compliance Officer or an independent investigation team to determine the nature and seriousness of the alleged misconduct.
• Investigation: If the report is deemed credible, a formal investigation will be conducted. This will include gathering relevant information, interviewing witnesses, and reviewing records or documents.
• Outcome and Action: Following the investigation, appropriate action will be taken, which may include corrective measures, disciplinary actions, or reporting to the relevant authorities, depending on the severity of the issue. The whistleblower will be informed of the outcome of the investigation, if applicable.
• Timeliness: Investigations will be conducted in a timely manner, and every effort will be made to conclude the process within a reasonable time frame. Updates will be provided to the whistleblower whenever appropriate.

6. False Reports

Coipa Italia S.p.A. & Gruppo Ventura takes all reports seriously and will conduct thorough investigations into all allegations. However, whistleblowers who knowingly submit false or malicious reports will face disciplinary actions. Submitting a false report damages the credibility of the process and undermines the integrity of the company.

7. Communication and Awareness

We are committed to ensuring that all employees, contractors, and partners are aware of this Whistleblowing Policy and feel encouraged to report misconduct.

• Training: We will regularly conduct training and awareness programs to ensure all employees understand their rights and obligations under this policy.
• Policy Accessibility: This policy will be accessible to all stakeholders on our internal portal and shared with employees during onboarding and training sessions.

8. Compliance with Legislation

Coipa Italia S.p.A. & Gruppo Ventura complies with relevant national and international laws and regulations, including the Whistleblower Protection Laws, Anti-Corruption Laws, and Data Protection Regulations, to safeguard whistleblowers and ensure accountability in the reporting process.

9. Continuous Improvement

Coipa Italia S.p.A. & Gruppo Ventura recognizes the importance of continually improving its whistleblowing processes. Regular reviews of this policy, along with feedback from employees and other stakeholders, will be conducted to ensure its effectiveness in protecting individuals and addressing misconduct.

Conclusion

This Whistleblowing Policy is an integral part of Coipa Italia S.p.A. & Gruppo Ventura’s commitment to maintaining a culture of integrity, transparency, and accountability. We encourage all employees, contractors, and stakeholders to report any concerns promptly and to contribute to the company’s efforts to uphold the highest ethical standards.

This document outlines the responsibilities of Coipa Italia S.p.A. & Gruppo Ventura, ensuring a safe, confidential, and effective channel for reporting misconduct and ensuring protection for those who come forward with legitimate concerns.