REPORTING - WHISTLEBLOWING

WHAT TO REPORT

Violations, alleged or actual:

• of the Code of Ethics, 
• of the Organization, Management and Control Model pursuant to Legislative Decree No. 231 (hereinafter also referred to as “Model 231”) and/or unlawful conduct relevant under Legislative Decree No. 231/2001, 
• of the relevant regulations and/or conduct that is not in line with the rules of conduct set forth in the Prevention Model pursuant to Article 7, paragraph 5, letter d) of the Federal Statute of the F.I.G.C. (hereinafter “Prevention Model”) or contrary to the ethical principles of loyalty, fairness and probity,
• of the Safeguarding Framework (a tool implemented by the Company to protect the welfare of children and prevent and counteract the phenomena of abuse, violence and discrimination), 
• that concern conduct that results in forms of secondary victimization at the expense of the Tesserati who submit or express the intention to submit a complaint to the judicial authority or an Internal Report on information of violations of the Safeguarding Framework or, in general, of instances of abuse, violence or discrimination carried out in the course of sporting activity, who assist other Tesserati in the complaint or Internal Reporting on the same information, who intervene as witnesses in proceedings regarding abuse, violence or discrimination or who take initiatives in relation to safeguarding policies,
• that relate to offenses that fall within the scope of the European Union or national acts indicated in Annex 1 to Legislative Decree no. 24/2023 or national acts that constitute implementation of the European Union acts indicated in the Annex to Directive (EU) 2019/1937, even if not indicated in Annex 1 to Legislative Decree no. 24/2023, related to the following areas: public procurement; financial services, products, and markets and prevention of money laundering and terrorist financing; product safety and compliance; transportation safety; environmental protection; radiation protection and nuclear safety; food and feed and animal health and welfare; public health; consumer protection; privacy and personal data protection; and network and information system security,
• that relate to acts or omissions affecting the financial interests of the European Union referred to in Article 325 TFEU specified in the relevant secondary legislation of the European Union,
• that relate to acts or omissions concerning the internal market referred to in Article 26(2) TFEU, including violations of European Union competition and state aid rules as well as violations concerning the internal market related to acts that violate corporate tax rules or mechanisms whose purpose is to obtain a tax advantage that frustrates the object or purpose of the applicable corporate tax law,
• Pertaining to acts or conduct that frustrate the object or purpose of the provisions set forth in the acts of the European Union indicated in the above points, which have occurred or are in the process of occurrence that may be detrimental to the Company.

Reports are received by the Whistleblowing Committee, which consists of 2 members: The Chairman of the Supervisory Board and the Chairman of the Company's Supervisory Board.

The Whistleblowing Committee will consider reports in non-anonymous form as well as in anonymous form.

PROTECTION OF THE REPORTER AND THE REPORTED

The Company guarantees the confidentiality of the reporter and the person to whom the report is addressed, if any. It is the responsibility of the reporter to be in good faith.

Reports that are manifestly false, or completely unfounded, will not be taken into consideration. The Company will also take appropriate action against those who threaten or carry out acts of retaliation against the whistleblower. Access to the IT platform is managed in a no-log mode in order to prevent identification of the reporter.

PROCEDURE TO BE FOLLOWED

To be aware of and properly handle any reports, please refer to the Policy “Whistleblowing System for Handling Reports” found within the Platform (Submit a Report > Final Step > Download Policy).

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