SISMA S.p.A., in implementing the provisions of the Legislative Decree. n. 24/2023, issued pursuant to Directive (EU) 2019/1937, regulated the “Whistleblowing” reporting process aimed at combating any illicit phenomena in the workplace, providing specific protection for the person who wishes to report the illicit activity (hereinafter the “Reporter”) without causing the same to fear incurring prejudicial consequences.

SISMA S.p.A. has therefore established a dedicated internal reporting channel aimed at guaranteeing the absolute confidentiality of the whistleblower and the person(s) involved, as well as of the content of the report itself and the related attached documentation, simultaneously ensuring the correct management of the report, in compliance with the provisions of the Law, as well as guaranteeing the whistleblower protection from any acts of retaliation.

The reports, which must be as detailed as possible, must concern violations that fall within the scope of application of art. 2 of the Legislative Decree. 24/2023, while those circumstances of a purely personal nature and which, in any case, are not provided for by the aforementioned Legislative Decree must be considered excluded from the scope of application (and protection) provided for by the aforementioned provision.

Please note that the legislation defines “violations” that can be reported under the so-called “Whistleblowing” mechanism as any behavior, whether active or inactive, that is likely to harm the public interest or the integrity of the Company, of which the whistleblowers become aware while working at Sisma S.p.A.

Reports can also be made anonymously, but they must be detailed to allow for an efficient investigation and proper verification of the validity of the reported facts. At the end of the report compilation process, a numeric code will be assigned that will allow the Reporting Party to access the report monitoring interface, ensuring so-called “depersonalization,” i.e., future access to the platform without specific credentials that could even indirectly allow identification.

The internal channel adopted, through which reports can be submitted, consists of an IT platform provided by a specialized third-party operator, accessible via the following link:

https://areariservata.mygovernance.it/#!/WB/SISMA

Management of the reporting channel and verification of the validity of the circumstances described in the reports are entrusted to the reporting manager, Attorney Luca Gioia of the Verona Bar Association (hereinafter the “Manager”), who meets the independence and professionalism requirements set forth by the applicable legislation and is specifically authorized by the Company.

The platform, through internal communication channels, allows the Manager to communicate with the Reporter, or other persons involved, and to report on the progress of the investigation, guaranteeing the confidentiality of the latter’s identity at all times.

The Data Controller shall verify the reported facts in compliance with the principles of objectivity and confidentiality, diligently following up on the reports received, and shall provide a response to the report—barring particularly complex cases—within three months of the date of acknowledgement of receipt of the report or, in the absence of such acknowledgement, within three months of the expiration of the seven-day period from the submission of the report.

It is recommended to access the platform using devices and internet connections not owned by Sisma S.p.A., since the data relating to your internet access history, in this case the Whistleblowing platform. They may otherwise be stored in the Internet browser available on the company device you are using and/or in the company firewall/proxy server. The Company may, in fact, have access, even involuntarily and unknowingly, to such data, directly or indirectly, through its system administrators for maintenance, technical assistance, and IT security purposes.

Please note that the protections provided by law are not granted when the Reporter is found to be criminally liable for the crimes of defamation and/or slander, or civilly liable for the same crimes in cases of fraud or gross negligence in the reporting. In cases where such liability is found, the Reporter may also be subject to disciplinary action.

The whistleblower has the right to use the external channel made available by ANAC in the following cases:

• when an internal reporting channel has not been activated within one’s work context, or if this, even if active, is not compliant;
• the report via internal channel was not followed up;
• reporting through internal channels may be ineffective or may lead to the risk of retaliation;
• the Reporting Party has reasonable grounds to believe that the violation may constitute an imminent or manifest danger to the public interest (for example, safeguarding the health and safety of people, protection of the environment, etc.).

All information on the tool made available by ANAC, as well as access to the reporting service itself, can be found at the following link:

https://www.anticorruzione.it/-/whistleblowing

Please consult the Company’s Regulations for further clarification on the whistleblowing process.

To view the Whistleblowing Privacy Policy click on WHISTLEBLOWING POLICY