A report can be sent, in written or oral form, through the platform accessible directly from the Forgialluminio 3 s.r.l. website contacts.

It is advisable for the reporter to provide as much information as possible regarding the incident (also following the instructions provided by the platform), taking care to describe in detail the facts to be reported.
The reporter can also indicate other people who can report on the incident and attach supporting files or documents to the report.

In addition to directors and members of corporate bodies, employees or collaborators of the Company who are or have been witnesses, even indirectly, of an offense or irregularity committed by the Company or one of its employees can make a report. Volunteers, interns and self-employed workers also fall into the aforementioned category.

The report can also be sent by external parties (for example, suppliers), as long as the information has been learned within their working context.

It is not necessary for the legal relationship with the Company to be in place at the time of reporting.

All behaviors, acts or omissions that harm the public interest or the integrity of the Company and which consist of violations of European legislation may be reported, such as:

• offenses falling within the scope of European Union acts relating to the following sectors: public procurement, services, products and financial markets and prevention of money laundering and terrorist financing, product safety and compliance, transport safety, protection environment, radiation protection and nuclear safety, food and feed safety and animal health and welfare, public health, consumer protection, protection of privacy and protection of personal data and security of networks and information systems;
• acts or omissions detrimental to the financial interests of the European Union;
• acts or omissions relating to the internal market (for example, competition and state aid violations);
• acts or behaviors that frustrate the object or purpose of the provisions set out in Union acts.
Significant illicit conduct pursuant to Legislative Decree 231/2001 or violations of the organization and management model adopted by the Company may also be reported.

ATTENTION: disputes cannot be reported regarding a personal interest of the reporting person and which relate exclusively to their individual employment relationship.

All reports are received by the Whistleblowing Officer who will send the reporting party an acknowledgment of receipt within 7 days.

As a preliminary matter, an analysis will be carried out to evaluate the validity of the report and its relevance to the reportable violations.

The Whistleblowing Officer could subsequently contact the whistleblower via the IT platform, in order to request additions or acquire further information. Once the report has been processed and the necessary investigations have been carried out, the person making the report will be informed of the outcome of the same.

The Whistleblowing Officer could also decide to archive the report if it is manifestly unfounded or irrelevant to the field of application.

All data relating to the report (identity of the subjects involved and content of the report) are protected by security measures and standards (e.g. encryption tools and other methods of protection from unauthorized access).

The identity of the whistleblower is known only by the person appointed to manage the report, who guarantees absolute respect for the confidentiality of the whistleblower and the other subjects mentioned.

When the report is sent, the platform will automatically assign the reporter a unique identification code which can be used by the reporter to perform subsequent accesses to the platform.

It is recommended to carefully store this code as it cannot be duplicated or recovered in any way in the event of loss.

During the reporting phase, the reporter can decide not to reveal their identity.

However, the Company encourages whistleblowers to prefer the disclosure of their identity, guaranteeing absolute respect for the whistleblower's confidentiality and the application of the protections provided for by Legislative Decree 24/2023, which otherwise could not be implemented against a unknown subject.

This also leads to greater effectiveness in the investigations that will subsequently be conducted by the Whistleblowing Officer, who will be able to investigate anonymous reports only if their content is clear, precise, complete and therefore suitable for bringing out specific facts and situations.

The Company does not tolerate incorrect use of the designated reporting channel, or use of said channel to make reports with a clearly defamatory and opportunistic nature.

If these elements are identified in the report or in any case it emerges that the whistleblower was driven by the intention to harm or unfairly blame other subjects, the Company reserves the right to take disciplinary and/or legal action against the whistleblower.

Furthermore, in the event that the responsibility of the whistleblower is ascertained (e.g. with a first instance sentence), the protections provided for by Legislative Decree 24/2023 will not be guaranteed.

An external report is a report addressed to ANAC (Italian National Anti-Corruption Authority).

A reporter can make a report to ANAC when:

• a reporting channel has not been established in your work context or, if activated, it does not comply with the provisions of Legislative Decree 24/2023;
• the reporting party has already made an internal report, but this has not been followed up;
• the reporting person has reasonable grounds to believe that, if he/she made an internal report, it would not be followed up effectively or could lead to a risk of retaliation;
• the reporting person has reasonable grounds to believe that the violation may constitute an imminent and obvious danger to the public interest.