Rules and processes to create shared value

Snaitech is committed to conducting its business activities with honesty and integrity, maintaining the highest standards of conduct and ethical behavior.

In order to prevent and combat unlawful conduct that is inconsistent with its values, Snaitech has established an independent system for receiving and managing reports of any conduct, including omissions, that constitutes or may constitute a violation of or inducement to violate laws and regulations, as well as values and principles enshrined in its Code of Ethics, the Organization, Management and Control Model drafted pursuant to Legislative Decree n. 231/2001, or internal policies and procedures.

Fundamental principles of Snaitech’s reporting system

• Protection of whistleblowers’ identity and confidentiality of information
  Snaitech guarantees the protection and confidentiality of the whistleblower’s identity. The whistleblower’s data is processed in accordance with the law and by adopting all useful measures to prevent disclosure of the whistleblower’s data and the content of the report. The whistleblower’s identity is not disclosed – without their explicit consent – to anyone who is not part of the authorized personnel responsible for receiving and following up on reports, unless disclosure represents a necessary and proportionate obligation imposed by EU or national law. In such cases, the whistleblower is notified in writing of the reasons for the disclosure of confidential data. Furthermore, reports are exempt from the right of access provided for, and insofar as applicable to the private sector, by Articles 22 et seq. of Law No. 241/1990, as well as Articles 5 et seq. of Legislative Decree No. 33/2013.
• Prohibition of retaliatory or discriminatory acts against whistleblowers
  Snaitech prohibits any form of retaliation or discrimination, active or omissive, even if only attempted or threatened, carried out by reason of the report and which causes or may cause the whistleblower, directly or indirectly, unjust harm. Such protection is guaranteed when the report (even if subsequently assessed as unfounded) was made in good faith. Snaitech guarantees the removal of the effects of any form of retaliation against the whistleblower. The commission of retaliatory or discriminatory acts against anyone who has made a report results in the initiation of disciplinary proceedings against the perpetrator of such acts and the imposition of related disciplinary measures (which may also result in dismissal), in accordance with applicable national employment law, and is reported to the competent authorities, as provided for by applicable legislation, and those responsible may be subject to civil and criminal sanctions. Protection measures for whistleblowers also apply, where appropriate, to other persons and situations (for example, to facilitators, i.e., those who assist the whistleblower in the reporting process, or to third parties connected with the whistleblower who could risk retaliation, such as the whistleblower’s colleagues or relatives).
• Protection of the reported person
  Reported persons are protected with regard to both the confidentiality of reports concerning them and any investigations conducted, as well as their protection from any retaliatory and/or defamatory actions. Following investigations into the merits of the report, the Whistleblowing Committee, i.e., the body responsible for receiving, analyzing, investigating, and responding to reports, if disciplinary proceedings are initiated, informs the person to whom the report refers, keeps them updated on developments in the proceedings, compatibly with the conduct of verification activities and collection of necessary evidence, so as to allow them to exercise their right of defense.
• Protection of the integrity of reports
  The reporting channels made available by Snaitech ensure that no report (from the notification stage to the decision stage) can be deleted and/or altered.
• Duty of independence and professionalism in managing and evaluating reports
  All persons involved, in any capacity, in the process of managing and evaluating reports must carry out their duties in compliance with duties of independence and ensuring accurate and efficient management and evaluation of all reports. In particular, the body responsible for managing reports is autonomous, dedicated, and composed of personnel specifically trained for this activity.

How to report

Snaitech invites anyone to promptly report irregularities or unlawful conduct, including potential ones, refraining from undertaking independent analysis and/or investigation initiatives. To this end, Snaitech has implemented specific communication channels for managing such reports in order to comply with Legislative Decree No. 24/2023, which implements EU Directive 2019/1937, namely:

•  Speak Up web platform
• Recorded telephone line/recorded voice messaging system accessible 24/7 at the following phone number 0039 8611835516
• Direct meeting with the Whistleblowing Committee, with possible involvement of the Supervisory Body (“OdV”) in the case of reports relevant under Legislative Decree 231/2001.

Reference regulations

• Criminal Code.
• Legislative Decree of March 10, 2023, No. 24 – Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council of October 23, 2019, on the protection of persons who report breaches of Union law and provisions regarding the protection of persons who report breaches of national regulatory provisions.
• Guidelines on the protection of persons who report breaches of Union law and protection of persons who report breaches of national regulatory provisions – procedures for submission and management of external reports approved by ANAC with Resolution No. 311 of July 12, 2023.
• Confindustria Operational Guide “New Whistleblowing Discipline” of October 2023
• Legislative Decree 231/2001 and subsequent amendments.
• EU Regulation 2016/679 – General Data Protection Regulation (or GDPR, General Data Protection Regulation) and Legislative Decree 196/03 as amended by Legislative Decree 101 of 2018 and any subsequent amendments.

Golden rules for a good report

Reports may be made anonymously, but in any case must be made in good faith and provide all elements known to the whistleblower that are useful for carrying out due and appropriate verifications to confirm the validity of the facts subject to the report.

Managing conflicts of interest

Snaitech pays great attention to ensuring that the management and evaluation of reports are entrusted exclusively to persons who are not in conflict of interest situations. Therefore, specific procedures are identified for managing reports that refer to one, more, or all members of the Whistleblowing Committee. These provisions also apply in the event that a conflict should arise during the conduct of investigations.

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