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f) shareholders and persons with functions of administration, direction, control, supervision, or representation,
even when such functions are exercised de facto at the Company (for example, members
of the Board of Directors).
The protection of reporting persons (Article 6 of this Policy) also applies when the report or
public disclosure of information occurs in the following cases:
a) when the legal relationship described above has not yet begun, if information about violations was
acquired during the selection process or in other pre-contractual phases;
b) during the probationary period;
c) after the termination of the legal relationship if information about violations was
acquired during the relationship itself.
2.SUBJECT MATTER OF THE REPORT AND EXCLUDED REPORTS
The reports indicated in the following table may be made:
Number of employees Subject matter of the report
with 50 or more
employees
– European and national offenses (see below
points a) and b)
(Article 3, paragraph 2, letter a), Legislative Decree No. 24/2023)
In more detail, the violations indicated in the previous table may concern:
a) violations of national or European provisions consisting of offenses concerning the following sectors:
financial services, products, and markets and prevention of money laundering and terrorist financing; product safety
and compliance; environmental protection; public health; protection of privacy and protection of personal data;
security of networks and information systems;
b) violations of European provisions consisting of: i) acts or omissions that harm the financial interests
of the Union; ii) acts and omissions concerning the internal market; iii) acts and conduct that undermine
the object or purpose of the provisions of Union acts in the sectors mentioned above;
c) unlawful conduct relevant under Legislative Decree 231/2001.
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3.REPORTING CHANNELS: INTERNAL, EXTERNAL, PUBLIC DISCLOSURE
The Company has established an internal reporting channel that guarantees the confidentiality of the identity of the
reporting person, the person involved, and the person otherwise mentioned in the report, as well as the
content of the report and related documentation.
Please note that Whistleblowingreports must first be made using the internal channel.
Reporting through the external channel, established and managed by ANAC, may only be made under certain
conditions and public disclosure under even more stringent conditions, without prejudice to the possibility of
filing complaints with the judicial authority.
4.CONTENT AND METHODS OF SUBMITTING REPORTS
A whistleblowing report may be made when the following conditions are met:
– when one has information, including well-founded suspicions, concerning violations committed or that, based on
concrete elements, may be committed, of national or European Union regulatory provisions
that harm the public interest or the integrity of the Company, as well as concerning conduct aimed
at concealing such violations
and
3
– such information was learned, or suspicions arose, within the work context.
Reports concerning the following will not be considered:
– disputes, claims, or requests related to a personal interest of the reporting person;
– individual employment or collaboration relationships of the reporting person with the Company, or with hierarchically
superior figures;
– aspects of the private life of the reported person, without any direct or indirect connection with
company and/or professional activities.
Furthermore, the following reports are not permitted:
– pretextual, defamatory, slanderous reports or those aimed solely at harming the reported person;
– reports concerning violations that the reporting person knows are not well-founded.
Share capital Euro 10,000,000 paid-in Euro 10,000,000 – Tax Code and Registration No. in the Verona Business Register 00684880230 – VAT No. IT00684880230SINCE 1979 SURFACE TECHNOLOGY AND DESIGN
Contents of the report
The report, on pain of inadmissibility, must contain:
1. the identifying information of the reporting person and contact details to which subsequent updates may be communicated;
2. a clear, complete, and detailed description of the facts subject to the report;
3. the circumstances of time and place in which the fact subject to the report occurred and, therefore, a
description of the facts subject to the report specifying details relating to circumstantial information and,
where present, also the manner in which one became aware of the facts subject to the report;
4. the personal details or other elements that allow identification of the person(s) considered responsible for the
reported facts;
5. indication of any other persons who may provide information about the facts subject to the report;
6. indication of any documents that may confirm the validity of such facts;
7. any other information that may provide useful confirmation of the existence of the reported facts.
8. in the case of using the analog channel, an express declaration of wishing to benefit from whistleblowing
protections, e.g., by including the wording “confidential to the report handler.”
Methods of reporting
Whistleblowingreports may be made using the following methods:
upon request of the reporting person through a direct meeting with the Whistleblowing Management Office (Paola
Dalla Valle and Annalisa Dalla Valle)
through ordinary mail by placing the report in two sealed envelopes, including, in the
first envelope, the identifying information of the reporting person together with an identity document;
in the second envelope, the subject matter of the report with related documentation;
both envelopes must then be placed in a third envelope bearing the wording
“Confidential to the Report Handler” and addressed to the Whistleblowing Management Office of Stone
Italiana spa.
Anonymous reports
Anonymous reports or reports from which it is not
possible to determine the identity of the reporting person will not be considered.
Anonymous reports will be registered by the report handler and retained.
In any case, protective measures for the reporting person apply only if the reporting person is
subsequently identified and has suffered retaliation.
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4SINCE 1979 SURFACE TECHNOLOGY AND DESIGN
Transmission of reports
Whistleblowing reports must be sent to the Whistleblowing Management Office, in accordance with the
adopted reporting channel.
Please note that the receipt of reports is suspended during the Company’s closure period.
5.REPORT MANAGEMENT
This procedure regulates the process of receiving, analyzing, and handling reports of unlawful conduct
of which the reporting person became aware within the work context.
In managing the internal reporting channel, the report handler (hereinafter also the
“handler” or “recipient”) operates as follows:
Receipt of the report
The recipient issues the reporting person an acknowledgment of receipt of the report within seven days from the
date of receipt. The acknowledgment will be sent to the contact details indicated by the reporting person and, if not indicated, the
report will be archived.
Anonymous reports are registered and their documentation is retained.
The Company will archive reports received by ordinary mail through appropriate tools
that ensure confidentiality (e.g., within archives protected by security measures).
Oral reports – in the forms indicated in this Policy – are documented by the
report handler who will prepare a record of the meeting that will be signed by both the handler and the
reporting person, and a copy will be provided to the latter.
Relations with the reporting person and supplementation of the report
The recipient maintains communications with the reporting person and may request, if necessary, supplementation.
In the case of a record prepared following a meeting with the reporting person, the latter may rectify the record
of the meeting by signing it.
Examination of the report
The recipient follows up on received reports, assessing the existence of the reporting person’s standing and
that the report falls within the scope of application of the regulation; this is followed by assessment of the circumstances of
time and place in which the fact occurred.
Following the preliminary verification:
– if the requirements are not met, the report is archived, with reasons provided;
reasons;
– if the requirements are met, an investigation is initiated.
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Investigation
The recipient ensures the proper conduct of the investigation through:
– collection of documents and information;
– involvement of external parties (in the event that it is necessary to avail oneself of the technical assistance of
third-party professionals) or other company functions, which have an obligation to cooperate with the report
handler;
– hearing of any other internal/external parties, where necessary.
The investigation is conducted in accordance with the following principles:
– necessary measures are adopted to prevent identification of the reporting person and the persons
involved;
– verifications are conducted by persons with the necessary training and activities are
tracked and properly archived;
– all parties involved in the assessment maintain confidentiality of the information received, unless
otherwise provided by law;
– verifications are conducted ensuring the adoption of appropriate measures for the collection, use,
disclosure, and retention of personal information and ensuring that the needs of the investigation
are balanced with those of privacy protection;
– appropriate measures are ensured to manage any conflicts of interest when the report
concerns the recipient.
Feedback to the reporting person
Within three months from the date of the acknowledgment of receipt or, in the absence of such acknowledgment, within three months from the expiration
of the seven-day period from submission of the report, the recipient provides feedback regarding
the report, communicating alternatively:
– archiving, providing the reasons for the decision, or
– the validity of the report and referral to the competent internal bodies for appropriate follow-up, or
– the activity carried out and still to be carried out (in the case of reports that require, for verification purposes,
a longer investigation activity) and any measures adopted (measures taken or
referral to the competent Authority).
6.Conflict of interest
If the report handler is in a conflict of interest, for example as a reported or
reporting person, the report will be handled by the Administrative Manager – Dr. Soliman Luisa.
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7.Protection of the reporting person and their liability
Reporting persons may not suffer any form of retaliation. The law provides that those who make
reports may not be sanctioned, demoted, dismissed, transferred, or subjected to other organizational measures
that end up having, directly or indirectly, negative effects on working conditions,
or effects of discrimination or retaliation against them.
The reasons that induce a person to report or denounce or publicly disclose are irrelevant for purposes
of their protection.
In judicial or administrative proceedings, or even in out-of-court proceedings concerning
the ascertainment of prohibited conduct against reporting persons, it is presumed that such conduct
was carried out because of the report, public disclosure, or complaint to the judicial
or accounting authority. The burden of proving that such conduct toward reporting persons is motivated by reasons
unrelated to the report, public disclosure, or complaint rests with the person who carried them out.
out.
However, alleged discriminatory or retaliatory measures suffered must be communicated to ANAC, to which
alone is entrusted the task of ascertaining whether the retaliatory measure is consequent to the reporting of misconduct and
applying, in the absence of proof by the Company that the measure taken is unrelated to the report, an
administrative pecuniary sanction.
Processing of personal data. Confidentiality
All processing of personal data will be carried out in accordance with Regulation (EU) 2016/679, Legislative Decree
June 30, 2003, No. 196 and Articles 13 and 14 of the Decree; furthermore, failure to comply with confidentiality obligations
may result in disciplinary liability, without prejudice to any additional liability provided by
law.
The information notice regarding the processing of personal data following a whistleblowing report is
available on company notice boards and on the website.
Internal and external reports and related documentation are retained for the time necessary for
processing the report and in any case no longer than 5 years from the date of communication
of the final outcome of the reporting procedure, in compliance with confidentiality and personal data protection obligations.
personal data.
Liability of the reporting person
The Company guarantees the reported person the right to be informed (within a reasonable period of time) regarding
any reports that involve them, guaranteeing the right to defense where disciplinary proceedings are initiated against them.
against them.
This procedure also leaves unaffected the criminal and disciplinary liability of the
reporting person in the event of slanderous or defamatory reports pursuant to the Criminal Code and Article
Share capital Euro 10,000,000 paid-in Euro 10,000,000 – Tax Code and Registration No. in the Verona Business Register 00684880230 – VAT No. IT00684880230
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Also sources of liability, in disciplinary proceedings and in other competent venues, are any forms of abuse
of the whistleblowing reporting procedure, such as manifestly unfounded reports and/or made
solely for the purpose of harming the reported person or other parties, and any other instance of improper use or
intentional instrumentalization of the procedure itself.
8.Sanctioning system
Regarding the sanctioning regime, ANAC applies the following administrative pecuniary sanctions:
• from 10,000 to 50,000 euros when it ascertains retaliation, or that the report was obstructed or there was an attempt
to obstruct it, or that the confidentiality obligation was violated;
• from 10,000 to 50,000 euros when it ascertains that reporting channels have not been established, that
procedures for making and managing reports have not been adopted, or that the adoption of such procedures
is not compliant, as well as when it ascertains failure to verify/analyze received reports;
• from 500 to 2,500 euros against the reporting person, when their civil liability is ascertained,
for willful misconduct or gross negligence, for defamation and slander.
9.Entry into force and amendments
This policy will enter into force on December 14, 2023. Upon its entry into force, all provisions previously
adopted on the matter, in whatever form communicated, must be considered repealed, if
incompatible or inconsistent, as they are replaced by the present provisions.
The Company will provide the necessary publicity and post the policy on the company notice board.
All employees may propose, when deemed necessary, reasoned additions to this policy; the
proposals will be examined by the Company’s General Management.
Share capital Euro 10,000,000 paid-in Euro 10,000,000 – Tax Code and Registration No. in the Verona Business Register 00684880230 – VAT No. IT00684880230
