The European Union, through Directive 2019/1937, has updated the regulations concerning the protection of

people who report violations of EU law, with the aim of establishing a minimum standard for protection

on whistleblower rights in all Member States. Italy has implemented the European Directive through Legislative Decree No. 10

March 2023, No. 24.

By adopting this Policy, STONE ITALIANA SPA has sought to comply with the aforementioned

regulatory requirements, as well as the guidelines provided by ANAC in this regard.

The goal is to provide whistleblowers—that is, those who report violations—with clear guidance

operational guidelines regarding the subject matter, content, recipients, and methods of submitting reports.

The procedure for handling reports ensures the confidentiality of the reporter’s identity from the very

upon receipt and in any subsequent contact. Pursuant to Article 5, paragraph 1, subparagraph (e) of the Decree, this

The policy therefore provides information on the channels, procedures, and requirements for filing reports

internal and external.

1. REPORTING ENTITIES

a) Reports may be filed by the following parties:

employees, including those who perform:

– part-time, intermittent, fixed-term, temporary agency, and apprenticeship work ,

casual workers (whose employment relationship is governed by Legislative Decree No. 81/2015);

– occasional services (pursuant to Article 54-bis of Decree-Law No. 50/2017, converted by Law No. 96/2017);

b) self-employed workers

– under a contract for services (Art. 2222 of the Civil Code);

– under a collaborative arrangement (as provided for in Article 409 of the Code of Civil Procedure), such as agency and representation relationships

commercial and other collaborative relationships that result in the provision of services

continuous and coordinated, primarily personal in nature, though not in a subordinate capacity;

– under a collaborative arrangement that involves the performance of work that is exclusively personal in nature,

ongoing, and the details of which are organized by the client;

c) d) e) employees who work for entities that provide goods or services or that

carry out projects that benefit society;

freelancers and consultants who provide services to the Company;

volunteers and interns, both paid and unpaid, who work for the Company;

STONE ITALIANA S.P.A.

Via Lavagno, 213 – 37040 Zimella – Verona, Italy – Tel. 39.0442 715715 – Fax 39.0442 715000 – stone@stoneitaliana.com – stoneitaliana.com

Share capital: 10,000,000 euros; paid-in capital: 10,000,000 euros – Tax ID and Verona Business Registry No. 00684880230 – VAT No. IT00684880230

1SURFACE TECHNOLOGY AND DESIGN SINCE1979

(f) the shareholder and persons holding positions of administration, management, control, oversight, or representation,

even if such functions are performed de facto at the Company (for example, members

(of the Board of Directors).

The protection of whistleblowers (Article 6 of this Policy) also applies if the report or the

Public disclosure of information shall occur in the following cases:

(a) when the legal relationship described above has not yet begun, if the information regarding the violations is

were collected during the selection process or at other pre-contractual stages;

b) during the probationary period;

c) after the termination of the legal relationship, if the information regarding the violations has been

acquired during the course of the employment relationship.

2. SUBJECT OF THE REPORT AND EXCLUDED REPORTS

The reports listed in the following table may be filed:

Number of employees Subject of the report

50 or more

employees

– European and national offenses (see below

items (a) and (b)

(Art. 3, para. 2, subpar. a), Legislative Decree No. 24/2023)

More specifically, the violations listed in the table above may relate to:

(a) violations of national or European provisions consisting of offenses relating to the following areas:

financial services, products, and markets; anti-money laundering and counter-terrorism financing; security

and product compliance; environmental protection; public health; privacy and data protection

personal data, network and information system security;

(b) violations of European provisions consisting of: (i) acts or omissions that harm financial interests

of the Union; (ii) acts and omissions concerning the internal market; (iii) acts and conduct that undermine

the subject matter or purpose of the provisions of Union acts in the sectors referred to above;

(c) unlawful conduct as defined in Legislative Decree No. 231/2001.

STONE ITALIANA S.P.A.

Via Lavagno, 213 – 37040 Zimella – Verona, Italy – Tel. 39.0442 715715 – Fax 39.0442 715000 – stone@stoneitaliana.com – stoneitaliana.com

Share capital: 10,000,000 euros; paid-in capital: 10,000,000 euros – Tax ID and Verona Business Registry No. 00684880230 – VAT No. IT00684880230

2SURFACE TECHNOLOGY AND DESIGN SINCE1979

3. REPORTING CHANNELS: INTERNAL, EXTERNAL, PUBLIC DISCLOSURE

The Company has established an internal reporting channel that ensures the confidentiality of the reporter’s identity

the person making the report, the person involved, and any person mentioned in the report, as well as the

the content of the report and the related documentation.

Please note that you must first file a report Whistleblowing using the internal channel.

Reports submitted through the external channel, established and managed by ANAC, may only be made under certain

conditions, and public disclosure under even stricter conditions, without prejudice to the possibility of

file complaints with the judicial authorities.

4. CONTENT AND PROCEDURES FOR SUBMITTING REPORTS

A whistleblowing report may be filed if the following conditions are met:

– when there is information, including reasonable suspicion, regarding violations that have been committed or that, on the

Based on concrete facts, violations of national or EU regulations may be committed

European Union regulations that harm the public interest or the integrity of the Company, as well as those concerning conduct aimed at

to conceal such violations

and

3

– such information was learned, or suspicions arose, in the workplace.

Reports concerning the following will not be considered:

– disputes , claims, or requests related to the reporter’s personal interests;

– the whistleblower’s individual employment or contractual relationships with the Company, or with individuals

hierarchically superior;

– aspects of the reported individual’s private life that have no direct or indirect connection to

business and/or professional activities.

In addition, the following reports are not permitted:

– baseless , defamatory, slanderous, or intended solely to harm the person reported;

– relating to violations that the whistleblower knows to be unfounded.

STONE ITALIANA S.P.A.

Via Lavagno, 213 – 37040 Zimella – Verona, Italy – Tel. 39.0442 715715 – Fax 39.0442 715000 – stone@stoneitaliana.com – stoneitaliana.com

Share capital: 10,000,000 euros; paid-in capital: 10,000,000 euros – Tax ID and Verona Business Registry No. 00684880230 – VAT No.IT00684880230 – SURFACE TECHNOLOGY AND DESIGN SINCE 1979

Contents of the report

The report must include the following, or it will be deemed inadmissible:

1. the identifying information of the person making the report and a contact address to which subsequent updates can be sent;

2. a clear, complete, and detailed description of the facts that are the subject of the report;

3. the time and place of the incident that is the subject of the report, and, therefore, a

a description of the facts that are the subject of the report, specifying the details regarding the circumstantial evidence and

including, where applicable, how the facts that are the subject of the report came to light;

4. personal information or other details that would allow for the identification of the person(s) believed to be responsible for the

reported incidents;

5. the names of any other individuals who can provide information regarding the facts described in the report;

6. a list of any documents that may confirm the validity of these facts;

7. Any other information that may provide useful insight into whether the reported facts are true.

8. When using the analog channel, an express statement of intent to benefit from the protections in

regarding whistleblowing, e.g., by including the phrase “confidential to the report handler.”

Reporting Procedures

Reports whistleblowing can be submitted in the following ways:

at the request of the whistleblower, through a face-to-face meeting with the Whistleblowing Management Office (Paola

Dalla Valle and Annalisa Dalla Valle)

by regular mail, placing the report in two sealed envelopes and including, in the

First envelope: the reporter’s identifying information along with a copy of their identification document;

in the second envelope, the subject of the report along with the relevant documentation;

Both envelopes must then be placed inside a third envelope with the following text written on the outside:

“For the Attention of the Whistleblower Coordinator” and addressed to Stone’s Whistleblowing Management Office

Italiana, Inc.

Anonymous reports

Anonymous reports, or reports from which it is not

It is possible to identify the person who made the report.

Anonymous reports will be recorded by the report administrator and retained.

In any case, the protective measures for whistleblowers apply only if the whistleblower is

was subsequently identified and suffered retaliation.

STONE ITALIANA S.P.A.

Via Lavagno, 213 – 37040 Zimella – Verona, Italy – Tel. 39.0442 715715 – Fax 39.0442 715000 – stone@stoneitaliana.com – stoneitaliana.com

Share capital: 10,000,000 euros; paid-in capital: 10,000,000 euros – Tax ID and Verona Business Registry No. 00684880230 – VAT No. IT00684880230

4SINCE1979: SURFACE TECHNOLOGY AND DESIGN

Submission of Reports

Whistleblowing reports must be submitted to the Whistleblowing Management Office, in accordance with the

reporting channel used.

Finally, please note that the acceptance of reports is suspended during the company’s closure period.

5. REPORT MANAGEMENT

This procedure governs the process of receiving, analyzing, and handling reports of misconduct

illegal activities of which the reporting individual has become aware in the course of their work.

As part of the management of the internal reporting channel, the reporting administrator (hereinafter also referred to as the

“operator” or “recipient”) operates as described below:

Receipt of the report

The recipient shall issue a notice of receipt of the report to the person who filed it within seven days of the

date of receipt. The notice will be sent to the address provided by the reporter; if no address is provided, the

The report will be closed.

Anonymous reports are recorded and documented.

The Company will file reports received by regular mail using appropriate methods

that ensure confidentiality (e.g., within archives protected by security measures).

A report made verbally—in the manner specified in this Policy—is documented by the

the person handling the report, who will prepare a meeting minutes to be signed by both the person handling the report and the

the person who filed the report, and a copy will be provided to that person.

Relations with the Reporting Party and Additions to the Report

The recipient maintains communication with the reporter and may request additional information, if necessary.

If a report is prepared following a meeting with the person who filed the complaint, that person may correct the report

of the meeting by signing it.

Review of the Report

The recipient follows up on the reports received, assessing whether the reporter has standing and

that the report falls within the scope of the regulation; this is followed by an assessment of the circumstances of

the time and place where the incident occurred.

Following the preliminary review:

– If the requirements are not met, the report isdismissed, with an explanation of the

reasons;

– If the conditions are met,the preliminary investigation is initiated.

STONE ITALIANA S.P.A.

Via Lavagno, 213 – 37040 Zimella – Verona, Italy – Tel. 39.0442 715715 – Fax 39.0442 715000 – stone@stoneitaliana.com – stoneitaliana.com

Share capital: 10,000,000 euros; paid-in capital: 10,000,000 euros – Tax ID and Verona Business Registry No. 00684880230 – VAT No. IT00684880230

5SINCE1979: SURFACE TECHNOLOGY AND DESIGN

Preliminary Investigation

The recipient ensures that the preliminary investigation is conducted properly by:

– the collection of documents and information;

– the involvement of external parties (in cases where it is necessary to seek technical assistance from

third-party professionals) or other company departments, which are required to cooperate with the manager of the

report;

– hearing from any other internal or external parties, as necessary.

The preliminary investigation is conducted in accordance with the following principles:

– the necessary measures are taken to prevent the identification of the whistleblower and the individuals

involved;

– The audits are conducted by individuals with the necessary expertise, and the activities are

properly tracked and archived;

– All parties involved in the evaluation shall maintain the confidentiality of the information received, except

unless otherwise provided by law;

– Audits are conducted in a manner that ensures the adoption of appropriate measures for the collection, use, and

the disclosure and preservation of personal information and ensuring that the needs of the investigation

are balanced against the need to protect privacy;

– Appropriate measures are in place to manage any conflicts of interest should the report

concerned the recipient.

Response to the Reporter

Within three months of the date of the acknowledgment of receipt or, in the absence of such acknowledgment, within three months of the deadline

Within seven days of the submission of the report, the recipient shall provide a response regarding the

report, providing one of the following:

– dismissal of the case, with an explanation of the reasons for the decision, or

– whether the report is well-founded and whether it should be forwarded to the appropriate internal bodies for further action, or

– the activities that have been carried out and those still to be carried out (in the case of reports that, for the purposes of verification,

a more time-consuming investigation) and any measures taken (actions taken or

(Referral to the competent authority).

6. Conflict of Interest

If the person handling the reports has a conflict of interest—for example, because they are the subject of the report or

If you are the person submitting the report, it will be handled by the Administrative Manager—Dr. Luisa Soliman.

STONE ITALIANA S.P.A.

Via Lavagno, 213 – 37040 Zimella – Verona, Italy – Tel. 39.0442 715715 – Fax 39.0442 715000 – stone@stoneitaliana.com – stoneitaliana.com

Share capital: 10,000,000 euros; paid-in capital: 10,000,000 euros – Tax ID and Verona Business Registry No. 00684880230 – VAT No. IT00684880230

6SURFACE TECHNOLOGY AND DESIGN SINCE1979

7. Protection of the Whistleblower and Their Liability

Whistleblowers must not be subject to any form of retaliation. In fact, the law provides that those who

whistleblowers cannot be penalized, demoted, fired, transferred, or subjected to any other measure

organizational practice that ends up having, directly or indirectly, negative effects on working conditions,

that is, discrimination or retaliation against them.

The reasons that lead a person to report, file a complaint, or make a public disclosure are irrelevant for the purposes of

of his protection.

In the context of judicial or administrative proceedings, or even out-of-court proceedings concerning

With regard to the investigation of prohibited conduct toward whistleblowers, it is presumed that such conduct

were taken as a result of the report, public disclosure, or complaint filed with the authorities

legal or accounting. The burden of proving that such conduct toward whistleblowers is motivated by reasons

Any information unrelated to the report, public disclosure, or complaint remains the responsibility of the person who provided it

to be.

Furthermore, any alleged discriminatory or retaliatory measures must be reported to ANAC, to which

It is solely responsible for determining whether the retaliatory measure is a consequence of the reporting of violations and

apply, in the absence of evidence from the Company that the measure taken is unrelated to the report, a

administrative fine.

Processing of Personal Data. Confidentiality

All processing of personal data will be carried out in accordance with Regulation (EU) 2016/679 and the decree

Legislative Decree No. 196 of June 30, 2003, and Articles 13 and 14 of the Decree; furthermore, failure to comply with the obligations of

Breaches of confidentiality may result in disciplinary action, without prejudice to any additional liabilities provided for by the

law.

The privacy notice regarding the processing of personal data following a whistleblowing report is

available on company bulletin boards and on the website.

Internal and external reports and the related documentation are retained for as long as necessary to

processing of the report, but in any case no later than 5 years from the date of notification

the final outcome of the reporting procedure, in compliance with the obligations of confidentiality and protection of

personal data.

Responsibilities of the Reporting Party

The Company guarantees the person reported the right to be informed (within a reasonable period of time) regarding

to any allegations involving him, ensuring his right to a defense should such proceedings be initiated against him

compare disciplinary measures.

This procedure also does not affect the criminal and disciplinary liability of the

the person making the report in the event of a false or defamatory report under the Penal Code and Article

Section 2043 of the Civil Code.

STONE ITALIANA S.P.A.

Via Lavagno, 213 – 37040 Zimella – Verona, Italy – Tel. 39.0442 715715 – Fax 39.0442 715000 – stone@stoneitaliana.com – stoneitaliana.com

Share capital: 10,000,000 euros; paid-in capital: 10,000,000 euros – Tax ID and Verona Business Registry No. 00684880230 – VAT No. IT00684880230

7SINCE1979: TECHNOLOGY AND SURFACE DESIGN

Any form of abuse is also grounds for disciplinary action and other appropriate measures

of the whistleblowing procedure, such as reports that are manifestly unfounded and/or made

for the sole purpose of harming the person reported or others, and any other instance of misuse or

deliberate manipulation of the procedure itself.

8. Penalty System

With regard to its penalty system, ANAC imposes the following administrative fines:

• from 10,000 to 50,000 euros when it determines that retaliation has occurred, or that the reporting of the incident was obstructed or an attempt was made to

to obstruct it or that the duty of confidentiality has been breached;

• from 10,000 to 50,000 euros when it determines that reporting channels have not been established, that they are not

procedures have been adopted to file and manage reports, or that the adoption of such procedures

is noncompliant, as well as when it determines that reports received have not been reviewed or analyzed;

• a fine of 500 to 2,500 euros against the reporting party, if the party’s civil liability is established, to

for defamation and slander, whether committed with intent or through gross negligence.

9. Effective Date and Amendments

This policy will take effect on December 14, 2023. Upon its entry into effect, all provisions in

Any previous provisions on this matter, regardless of how they were communicated, shall be deemed repealed if

incompatible or inconsistent, as they are superseded by these.

The Company will ensure that the policy is properly publicized and posted on the company bulletin board.

All employees may propose, when deemed necessary, well-reasoned additions to this policy; the

Proposals will be reviewed by the company's senior management.

This policy is, however, subject to periodic review.

Zimella, December 14, 2023 STONE ITALIANA SPA

Rev. 0

STONE ITALIANA S.P.A.

Via Lavagno, 213 – 37040 Zimella – Verona, Italy – Tel. 39.0442 715715 – Fax 39.0442 715000 – stone@stoneitaliana.com – stoneitaliana.com

Share capital: 10,000,000 euros; paid-in capital: 10,000,000 euros – Tax ID and Verona Business Registry No. 00684880230 – VAT No. IT00684880230