AT International S.r.l. is committed to operating ethically and responsibly and requires its staff and associates-such as the governing body, executives, supervisory bodies, managers, employees, and other associates-as well as its business associates to operate accordingly and in compliance with:

• Applicable laws and regulations;
• Measures of Authorities;
• D. Lgs. n. 231/2001 and company procedures.

WHAT TO REPORT.

AT International S.r.l. encourages its stakeholders to report any violations or suspected violations of national or European Union regulatory provisions that harm the public interest or the integrity of the public administration or the Company, of which they have become aware in the context of their own work context, public or private.

To this end, AT International S.r.l. has implemented specific rules and a whistleblowing process to provide potential whistleblowers with secure channels that guarantee the confidentiality of their identity and the information contained in the report and protection from retaliation and discrimination.

HOW TO REPORT.

1. Via platform

AT International S.r.l. has provided a dedicated IT platform, managed by a specialized third party, in order to ensure the effectiveness and confidentiality of the reporting process, as well as to allow access to it by all those who wish to make a report. The platform is accessible from both www.atvetro.it and the corporate intranet.

Although anonymous reports are accepted, AT International S.r.l. encourages whistleblowers to prefer named ones, which benefits the speed and effectiveness of investigations.

1. Other internal communication channels

Reports falling under the discipline of whistleblowing can also be made by Regular Mail, to the address: Lawyer Enrico Bevilacqua, Piazzale Ellero dei Mille no. 6, 33170 Pordenone (c.a. Manager of the internal whistleblowing reporting channel of AT International S.r.l.), taking care to adopt the precautions provided for in the Procedure for the management of reports, in order to ensure the confidentiality required by D. Lgs. n. 24/2023 and confidential protocoling of the report by the Manager of the internal reporting channel.

Should through the above channels, reporting parties request a direct meeting, the Manager of the internal reporting channel will make himself available to collect the report.

Formalities

N.B. The onus is on the reporter to specify within the report whether he or she wishes to keep his or her identity confidential and benefit from the protections provided in the event of any retaliation.

In fact, in the absence of such an indication, the report could be treated as an ordinary report, outside the scope of Legislative Decree. n. 24/2023, resulting in the inapplicability of the relevant guarantees and protections.

This specification also allows, where the report is mistakenly sent to a non-competent person, for timely transmission by the latter to the person authorized to receive and handle whistleblowing reports, subject to the confidentiality guarantees provided by law.

WHAT DOES AT INTERNATIONAL DO AFTER RECEIVING THE REPORT?

The Whistleblowing process consists of the following steps:

• Receipt of reports;
• Preliminary assessment;
• Survey;
• Closure of reports.

The Manager of the internal reporting channel shall issue the reporter with an acknowledgement of receipt of the report within seven days from the date of receipt of the report and initiate the investigation, carrying out the investigations aimed at ascertaining objectively whether or not the reported facts are true. The results of the survey are submitted to the relevant function(s) by subject matter for determination of any necessary measures.

WHAT NOT TO REPORT

Reports other than those described above, particularly those referring to commercial inquiries and complaints, will not be processed. In the event of unfounded reports, made in bad faith or with gross negligence, AT International S.r.l. reserves the right to take action in defense of its own interests or those of injured parties.

GUARANTEES AND SAFEGUARDS

The Manager of the internal reporting channel, as well as all AT International S.r.l. personnel who, in various capacities, should be involved in the management of reports, is required to guarantee confidentiality on the existence and content of the report and related documentation, as well as on the identity of the reporting parties (if communicated), facilitators (if any), reported parties and/or, in any case, all parties involved or mentioned in the report.

AT International S.r.l., moreover, prohibits and sanctions any form of retaliation or discrimination against anyone who has made a report (as well as anyone who has cooperated in ascertaining the facts reported) based on a reasonable belief that the information about the violations reported, disclosed or denounced, was true and fell within the objective scope of application of Legislative Decree. n. 24/2023, regardless of whether the report was later proven to be well-founded or not.

COMMUNICATION OF RETALIATION

In any case, individuals who have suffered or believe they have suffered retaliation as a result of a public report, complaint or disclosure may report such retaliation to ANAC.

Specifically, the following individuals may make such a communication to ANAC’s address if they believe they have suffered retaliation as a result of a report, whistleblower or public disclosure: whistleblowers, facilitators, people in the same work environment, co-workers (including legal entities in cases where they are entities owned by the whistleblower), whistleblower, public discloser or entities in which they work or entities that operate in the same work environment.

In making the retaliation disclosure, it is necessary to acknowledge the consequentiality between the report, whistleblowing, public disclosure made and the alleged retaliation. Thus, the whistleblower must provide ANAC with objective evidence from which it is possible to infer the consequentiality between the report, whistleblowing, public disclosure made and the complained of retaliation.

In such cases, upon receipt of the notice, ANAC carries out the investigations attributed to it by the law and, if it ascertains the retaliatory nature of acts, measures, behaviors, omissions adopted, or even only attempted or threatened, their nullity and the application of a pecuniary administrative sanction follows.

More information about the external reporting channel set up by ANAC is available on the website of the National Anti-Corruption Authority (ANAC).

MAKE A REPORT

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REPORTING MANAGEMENT PROCEDURE

WHISTLEBLOWING

by

AT INTERNATIONAL S.r.l.

1. FOREWORD

With the adoption of Legislative Decree no. 24 of March 10, 2023, the legislature implemented in our law the Directive (EU) 2019/1937 (so-called “Whistleblowing Directive”) regarding the protection of individuals who report violations of Union law that come to their attention in a public or private employment context.

The objective of the Directive is to create a system of rules that are as uniform as possible at the European level, aimed at ensuring the protection ofwhistleblowers, with a view to protecting the freedom of expression of the thoughts ofwhistleblowersand strengthening legality and transparency in the exercise of business activities, as a function of crime prevention.

The D. Lgs. March 10, 2023, no. 24, effective as of July 15, 2023, repealed and amended the previous national regulations, encapsulating in a single piece of legislation-applicable to both the public and private sectors-the protection regime for individuals who report misconduct that violates not only European but also national provisions, provided that such reports are based on well-founded grounds and relate to conduct that potentially harms the public interest or the integrity of the entity.

Today, therefore, the discipline of whistleblowing-previously dictated, for the sole purpose of the administrative liability of entities, by Art. 6, paragraph 2-bis, Legislative Decree. n. 231/2001 – has acquired a much broader subjective (as well as objective) scope than in the past.

In particular, in the private sector, companies that do not have an organizational and management model under Leg. n. 231/2001, have employed, in the past year, an average of at least 50 employees with permanent or fixed-term employment contracts.

Therefore, in accordance with the provisions of D. Lgs. March 10, 2023, no. 24, AT INTERNATIONAL S.r.l. has established its own internal channel for handling relevant reports under the said regulations.

2.  PURPOSE
   
   The purpose of this procedure is to regulate the process of sending, receiving, analyzing and processing, as well as the manner of handling the preliminary investigation, of reports concerning violations of national or European Union regulatory provisions that harm the public interest or the integrity of the Company, of which the reporting parties have become aware in the context of their work context, in compliance with current regulations applicable to the subject and object of the report as well as the regulations on the protection of personal data.
   
   

3. SCOPE OF APPLICATION

This procedure applies to all partners, members of the Administrative Body, members of the Board of Statutory Auditors and employees of AT INTERNATIONAL S.r.l, as well as to all those who, although not falling within the category of employees, work for AT INTERNATIONAL S.r.l. and are under the control and direction of the company (e.g. interns, contract and project workers), as well as to those who, although external to the Company, work, directly or indirectly, for AT INTERNATIONAL S.r.l. or with AT INTERNATIONAL S.r.l. (e.g. professionals, consultants, agents, suppliers, business partners, customers, etc.).

This procedure also applies, likewise, to all persons who perform their work in a public or private entity and who have been (or believe, in good faith, that they have been) witnesses to an offence or irregularity referable to AT INTERNATIONAL S.r.l. personnel.

This list includes, in addition to employees, self-employed workers, those who have a professional relationship with the Company, freelancers and consultants, volunteers, trainees, including unpaid ones, as well as partners and persons with administrative, control, supervisory or representative functions, even if only de facto.

Finally, this Procedure applies to individuals whose employment relationship has ended, if the report concerns incidents that occurred during the course of the relationship, and to applicants for employment who have acquired the information about violations during the selection process or at other stages of pre-contract negotiations and who may suffer retaliation (such as, for example, negative job references or boycotts).

The management of reports and the related processing of personal data and information collected is carried out by AT INTERNATIONAL S.r.l., in compliance with the applicable legal provisions, including the legislation on the protection of personal data and, in particular, Legislative Decree 30/06/2003 no. 196 as amended (Personal Data Protection Code) and the European Regulation 2016/679 (GDPR).

4. OBJECT OF THE REPORT
   
   

Through the Whistleblowing channel described by this procedure, in accordance with Art. 1, para. 1, Legislative Decree. March 10, 2023, no. 24, violations or suspected violations of national or European Union regulatory provisions that harm the public interest or the integrity of the public administration or the Company, of which the reporting persons have become aware in the context of their own public or private work environment, may be reported.

In more detail, they can be the subject of a report:

1. The violation of the EU regulations listed in Annex 1 to Leg. n. 24/2023 and any national provisions implementing them. These are violations of national and European provisions consisting of offenses relating to the following areas: public procurement; services, products and financial 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 safety and animal health and welfare; public health; consumer protection; privacy and data protection; and network and information system security;
2. Violations of European provisions consisting of:
3. acts or omissions affecting the financial interests of the European Union (Art. 325 TFEU fight against fraud and illegal activities affecting the financial interests of the EU) as identified in EU regulations, directives, decisions, recommendations and opinions;
4. acts and omissions concerning the internal market that impair the free movement of goods, persons, services and capital (Article 26(2) TFEU). This includes violations of EU competition and state aid rules, corporate tax, and mechanisms whose purpose is to obtain a tax advantage that defeats the object or purpose of the applicable corporate tax law;

• Acts and conduct that frustrate the object or purpose of the provisions of Union acts in the areas referred to in Art. 2(1)(a), nn. 3), 4) and 5), of Legislative Decree. March 10, 2023, no. 24;

1. Violations of national provisions consisting of:
   1. Administrative, accounting, civil or criminal offenses;
   2. Illegal conduct relevant under Leg. 231/2001.

Subject of the report, moreover, may be-always subject to the limitation of the matters indicated above-both violations that have been committed and those that have not yet been committed but that the whistleblower reasonably believes could be committed on the basis of concrete evidence, as well as, further, conduct that should be aimed at concealing violations.

Reports will not be processed:

• other than the cases described above and, in particular, those related to an interest of a personal nature of the reporting person and/or those referring to requests, complaints or grievances of a commercial nature.
• having to do with news that is patently unsubstantiated, information that is already in the public domain, as well as information acquired only on the basis of indiscretions or rumors that are scarcely reliable (so-called “rumors”).
  
  

5. MODES OF OPERATION
   
   

The process consists of the following stages: submission of reports; receipt of reports; preliminary assessment; investigation; and closure of reports.

1. A) Submission of reports

AT INTERNATIONAL S.r.l., in order to ensure the effectiveness of the reporting process and provide broad and indiscriminate access to all those who wish to make a report, has made available a plurality ofalternative communication channels among them and, precisely:

1. IT platform (managed by MYGO S.r.l., with registered office in Rome, Piazza Crati no. 20, Tax Code and VAT Number 14356531005 (tel. 0645214912) accessible from the website atvetro.it, which allows people to report both in written and oral form through a voice messaging system.

If the reporter decides to make the report through the IT platform, it is hereby made known that:

• On the main page of the platform the reporter can:
  1. Start the procedure for creating a new report;
  2. access a previously submitted report, interact with the Manager of the internal reporting channel, receive his/her communications, requests and feedback as well as monitor the progress of the report.

For these activities, the unique numeric code provided to the reporter upon completion of the creation of the report must be entered in the space provided.

• In the case of new reporting:
• the reporter is offered a questionnaire to fill out (mandatory fields are marked with an asterisk “*”);
• upon completion of the questionnaire, a unique numeric code is issued which the reporter is required to copy and keep securely in order to later access his or her report as the same constitutes the only key to access his or her report.
• in the case of accessing an existing report, the reporter can review the information he or she has entered, interact with the Manager of the internal reporting channel, and enter any new information and/or documents in the appropriate fields.

2. Regular mail to the address: Enrico Bevilacqua, Piazzale Ellero dei Mille no. 6, 33170 Pordenone (Italy) (c.a. Manager of the internal reporting channel of AT INTERNATIONAL S.r.l.).

If the reporter opts for this second channel of communication, in order to ensure the confidentiality required by Legislative Decree. n. 24/2023 and in view of the confidential filing of the report by the Manager of the internal reporting channel, it is necessary that the report be placed in two sealed envelopes: the first with the identifying data of the reporter, together with a photocopy of the identification document; the second with the report, so as to separate the identifying data of the reporter from the report. Both should then be placed in a third sealed envelope marked “confidential” on the outside to the Manager of the internal reporting channel. The report is then subject to confidential protocol by the manager.

Whichever communication channel is chosen by the reporting party, reports will be received by AT INTERNATIONAL S.r.l.’s Internal Reporting Channel Manager, Lawyer Enrico Bevilacqua, with Offices in Piazzale Ellero dei Mille no. 6, 33170 Pordenone (Italy).

Monitoring on the functionality of the IT communication channel is provided by MYGO S.r.l., with registered office in Rome, Piazza Crati no. 20, Tax Code and VAT Number 14356531005 (tel. 0645214912, PEC: mygosrl@legalmail.it) who should be contacted in case of any malfunctions.

In case the reporter uses the dedicated IT platform to send the report, the Manager of the internal reporting channel of AT INTERNATIONAL S.r.l. always informs the sender that the report has been taken over. Although anonymous reports are accepted, AT INTERNATIONAL S.r.l. encourages whistleblowers to prefer named ones, which benefits the speed and effectiveness of investigations, as well as a more effective guarantee of confidentiality.

Finally, through the above channels it is also possible for the reporter to request a face-to-face meeting; in such cases, the Manager of the internal reporting channel will be available to meet with the reporter to collect the report.

Safeguards and protective measures to protect the reporter are outlined in Section 7 below, to which reference is made.

Reports received outside the prescribed channels. The personnel of AT INTERNATIONAL S.r.l. who should receive a report that has transited outside the prescribed channels – where the reporter has expressly stated that he or she wishes to benefit from the protections in the matter whistleblowing or such intention can be inferred from the report itself – considers the report as a “report whistleblowing” and transmits it without delay (at the latest, by the seventh day after its receipt), in original and with any attachments, to the Manager of the internal reporting channel in accordance with the criteria of maximum confidentiality and in a manner appropriate to protect the reporter and the identity and honorability of the reported persons, without prejudice to the effectiveness of subsequent investigative activities.

Content of reports. The reporter makes reports by providing the information available to him or her based on good reason and truthful and substantiated news. The subsequent stages, of preliminary verification and ascertainment, are facilitated by the receipt of reports with precise and detailed content, such as but not limited to:

• Circumstances of time and place in which the reported event occurred;
• description of the fact;
• generalities or other elements that make it possible to identify the person to whom the reported facts can be attributed.
• Indication of any other persons who can report on the facts being reported;
• indication or, if in possession, provision of any documents supporting the report;
• in cases where the report is not anonymous, identifying elements of the reporter (e.g., generalities and contact details).

The information may cover both violations that have been committed and those that have not yet been committed that the whistleblower reasonably believes could be committed based on factual evidence.

Those items involving conduct designed to conceal violations may also be subject to reporting, public disclosure or complaint.

Information on reportable or reportable violations does not include information that is patently unsubstantiated, information that is already totally in the public domain, as well as information acquired only on the basis of poorly reliable indiscretions or rumors (so-called “rumors”).

In case of unfounded reports, made in bad faith or with gross negligence, AT INTERNATIONAL S.r.l. reserves the right to act in defense of its interests and to protect the injured parties.

1. B) Receipt of reports and preliminary assessment

The Manager of the internal reporting channel promptly analyzes the reports received and issues the reporter with an acknowledgement of receipt of the report within seven days from the date of receipt of the report.

Subsequently, based on the content of the report:

1. if the report has precise, circumstantiated and verifiable content, and makes reference to relevant facts pursuant to the Whistleblowing regulations, initiates the relevant investigation (pursuant to letter C below), being able to make use of the support of the relevant corporate functions and/or external consultants, depending on the nature and content of the report;
2. If the report has unsubstantiated and/or unverifiable content:

• if the reporter could not be reached to provide necessary additions, files the report;
• when, on the other hand, the whistleblower can be reached to provide the necessary additions, it asks the whistleblower for additional information and/or clarifications and, once it has obtained such information and ascertained that the report refers to relevant facts under the Whistleblowing regulations, it initiates the relevant investigation (pursuant to letter C below).
• if the report relates to facts which – although concerning AT INTERNATIONAL S.r.l. – do not fall within the scope of this document (so-called. “non inherent reports“, such as, by way of example but not limited to, complaints of a commercial nature, business proposals, marketing activities), it shall forward it to the corporate function competent to know about the issue, which shall provide all the necessary clarifications and/or support and, at the outcome of its activities, shall provide an update to the Manager of AT INTERNATIONAL S.r.l.’s internal reporting channel about the results of its activities;

1. if on the reported facts the existence of ongoing investigations by Public Authorities (e.g., judicial authorities and/or administrative bodies) is known, refrain from dealing with the investigation;
2. if the report relates to previously known and fully established facts, without the new report having added or allowing for additional elements or aspects to what was already known (so-called “outdated reports“), files the report.

Without prejudice to what is provided in the case of initiating the investigation, the Manager of the internal reporting channel, in all cases where the report is dismissed, shall equally provide feedback to the report within three months from the date of the notice of receipt or, in the absence of such a notice, within three months from the expiration of the seven-day period from the submission of the report, communicating its decision and giving reasons for the choices made.

1. C) Investigation

In all cases in which the report has – also as a result of requests and the obtaining of the necessary additions – a precise, circumstantiated and verifiable content, and refers to relevant facts pursuant to the Whistleblowing regulations, the Manager of the internal reporting channel initiates the relevant investigation, being able to make use of the support of the competent corporate functions and/or external consultants, depending on the nature and content of the report. In any case, the involvement of such relevant corporate functions and/or external consultants shall take place with the utmost respect for the guarantees of confidentiality and protective measures for the protection of the reporter better depicted in paragraph 7 below.

The purpose of the investigation is to perform the in-depth investigations aimed at objectively ascertaining whether the reported facts are true or not.

The Manager of the internal reporting channel maintains interlocutions with the whistleblower and, throughout the course of the investigation, may request from the whistleblower any additions it deems necessary for the purposes of the investigation; may also avail itself – also through the heads of the competent corporate functions or external consultants who support the investigative activity – of all the investigative means it deems appropriate and proportionate to the nature and gravity of the facts reported, taking care never to reveal the identity of the reporting person or any other information from which such identity may be inferred, directly or indirectly (except in cases where the reporting person has expressly given his or her consent to the disclosure to third parties of his or her identity).

1. D) Closure of reports

Within three months from the date of the acknowledgement of receipt or, in the absence of such an acknowledgement, within three months from the expiration of the seven-day period from the submission of the report, the Manager of the internal reporting channel shall provide feedback to the whistleblower, informing him/her of the outcome of his/her report.

Such “acknowledgement” may consist of notice of dismissal, initiation of an internal investigation and possibly its findings, steps taken to address the issue raised, referral to a competent authority for further investigation.

It should be noted, however, that the feedback may also be merely interlocutory, as it may concern information on the activities described above that AT INTERNATIONAL S.r.l. intends to undertake and the status of the preliminary investigation. In such a case, the outcomes will still be communicated to the reporting person once the Manager of the internal reporting channel has completed the investigation.

As a result of the investigation phase, the Manager of the internal reporting channel:

• should the content of the report be confirmed, refers the definition of any necessary measures to the relevant function(s) by subject, in compliance with the articulation of powers and responsibilities and the system of proxies in force;
• should areas of weakness and/or points for improvement in the company’s internal organizational arrangements emerge during the course of the assessment (regardless of the outcome), it may request implementation of the necessary improvement actions.

The Manager of the internal reporting channel proceeds to close the report, classifying it as “Founded” or “Unsubstantiated” and “With Actions” or “Without Actions,” whether it is to improve organizational arrangements and internal controls or otherwise (e.g., adoption by the company of disciplinary sanctions and/or reporting to the Judicial Authority).

Finally, communication flows are activated between the Manager of the internal reporting channel, the Administrative and Control Body and other actors in the internal control system so that they can take the initiatives they deem appropriate for prevention purposes.

6. RECORD KEEPING
   
   

The Manager of the internal reporting channel shall ensure that the original documentation related to the reports, as well as the working papers related to the investigation and any audits referred to the report, are kept in special computer files with the highest standards of security and confidentiality consistent with current regulatory provisions.

The personal data of the individuals involved in any capacity in the report and subsequent investigation activities(i.e., reporter, reported and third parties), are processed and stored in accordance with the legislation on the protection of personal data and, in particular, Regulation (EU) 2016/679, Legislative Decree. June 30, 2003, no. 196 and D. Lgs. May 18, 2018, no. 51.

In any case, if the reported facts do not fall within the scope of the Whistleblowing regulations and/or cannot be ascertained, any personal data contained within the report will be deleted or anonymized within 30 days of its receipt.

Likewise, if the report is found to be unfounded and no judicial or disciplinary action is taken by the company, the personal data will be deleted or anonymized within 30 days after the investigation process is completed.

The reports-deprived of all personal data of the individuals involved, in the cases described above, or complete with the personal data of the individuals involved, in other cases-as well as the related documentation will be kept for as long as necessary for the processing of the report and, in any case, no longer than five years from the date of the communication of the final outcome of the reporting procedure.

7. GUARANTEES AND SAFEGUARDS
   
   

The guarantees and protections described in the following sections. a), b), (c) and d), shall apply not only when the employment, collaboration contract or other relationship between the Company and the reporting person is in progress at the time of reporting but also when the reporting, reporting to the judicial or accounting authorities or public disclosure of information takes place:

• when the legal relationship has not yet begun, if information about violations was acquired during the selection process or at other pre-contractual stages;
• During the probationary period;
• subsequent to the dissolution of the legal relationship if the information on violations was acquired during the course of the relationship.

The onus is on the reporter to specify within the report whether he or she wishes to keep his or her identity confidential and benefit from the protections provided in the event of any retaliation.

In fact, in the absence of such an indication, the report could be treated as an ordinary report, outside the scope of Legislative Decree. n. 24/2023, resulting in the inapplicability of the relevant guarantees and protections.

This specification also allows, where the report is mistakenly sent to a non-competent person, for timely transmission by the latter to the person authorized to receive and handle whistleblowing reports, subject to the confidentiality guarantees provided by law.

1. (a) Guarantee of confidentiality

The Manager of the internal reporting channel, as well as all AT INTERNATIONAL S.r.l. personnel who, in various capacities, should be involved in the management of reports, is required to guarantee confidentiality on the existence and content of the report and related documentation, as well as on the identity of the reporting parties (if communicated), facilitators (if any), reported parties and/or, in any case, all parties involved or mentioned in the report.

Any communication regarding the existence and content of the report, as well as the identity of the reporters (where disclosed) and reported, must strictly follow the “need to know” criterion. To this end, in all cases in which it is necessary to provide communications regarding a report, the Manager of the internal reporting channel requests in advance explicit authorization from the Data Controller – AT INTERNATIONAL S.r.l., based in Viale Europa no. 20, 33070 Brugnera (PN), P.IVA 01788390936, tel. +39 0434/606511 – who notes in the appropriate Register of Authorized Persons the list of persons to whom it was necessary to provide communications regarding each report and the information communicated.

1. (b) Protection of the reporter

AT INTERNATIONAL S.r.l. and the Manager of the internal reporting channel guarantee the confidentiality of the reporter’s identity from the stage of receipt of the report, in compliance with current legal provisions.

For reports transmitted through the information technology platform referred to in paragraph 5(A) above, the confidentiality of the identity of the reporter (as well as the content of the report) is protected in the following ways:

• the platform is issued by a specialized entity that is third and independent from AT INTERNATIONAL S.r.l;
• the platform is ISO 27001 and ISO 9001 certified and guarantees complete anonymity in access. In addition, connection to the platform is not subject to any type of monitoring, even if access is made from a computer connected to the company network or through a link available on the atvetro.it website;
• the platform ensures high security standards, employing advanced encryption algorithms and other methods to protect against unauthorized access;
• the reporter, if he or she feels so inclined, may indicate his or her name within his or her report or decide to remain anonymous.

For reports transmitted through paper and electronic mail channels, the confidentiality of the identity of the reporter (as well as the content of the report) is protected in the following ways:

• paper correspondence addressed to the Manager of the internal reporting channel is delivered to him unopened (as delivered by the postal service).

In all cases in which the name of the reporter has been disclosed, in the processing of reports by the staff of AT INTERNATIONAL S.r.l. that may be involved in the management of reports, the same name is separated from the content of the report and replaced with the alphanumeric code assigned to it at the stage of the first annotation in the appropriate Register.

1. (c) Protecting the reporter from retaliation and discrimination

In compliance with the law and the provisions of Paragraph 8 below, AT INTERNATIONAL S.r.l. prohibits and sanctions any form of retaliation or discrimination against anyone who has made a report (as well as anyone who has cooperated in ascertaining the reported facts) based on a reasonable belief that the information about the reported violations disclosed or reported was true and within the objective scope of application of Legislative Decree. n. 24/2023, regardless of whether the report was later proven to be well-founded or not.

In particular, in addition to the reporting party, AT INTERNATIONAL S.r.l. prohibits and sanctions any form of retaliation or discrimination directed against:

• of so-called “facilitators,” i.e., any individuals who, if necessary, assist the reporter in the reporting process, providing advice and support, and who operate within the same work context (e.g., a colleague from a different Office than the reporter’s who assists the reporter in the reporting process);
• of persons in the same work environment as the reporting person, the one who has made a complaint to the judicial or accounting authority, or the one who has made a public disclosure and who are related to them by a stable emotional or kinship relationship within the fourth degree;
• of co-workers of the reporting person or the person who has made a complaint to the judicial or accounting authority or made a public disclosure, who work in the same work environment as the reporting person and who have a usual and current relationship with that person;
• of the entities owned by the reporting person or the person who filed a complaint with the judicial or accounting authorities or made a public disclosure or for which the same persons work, as well as entities that operate in the same work environment as the aforementioned persons.

Where, in particular, the bona fide reporter is an employee of the Company, the Manager of the internal reporting channel (making use of the relevant Company Functions) will monitor the employee’s work life for a period of 2 years from the date of the report, to prove the absence of discriminatory actions or other forms of retaliation resulting from the report. Where the whistleblower is an employee, he or she shall not be dismissed, nor shall he or she be subjected to any change in job duties, or be suspended, transferred, or subjected to any other organizational measure having direct or indirect adverse effects on working conditions, unless the decision is motivated by reasons other than and in addition to the whistleblowing (and evidence of which is given to the Manager of the internal reporting channel).

In order to access these protections, however, it is necessary not only that the report was made on the basis of a reasonable belief that the information about the reported violations disclosed or reported was true and within the objective scope of Legislative Decree. n. 24/2023, but also that the public reporting or disclosure was made in compliance with the regulations set forth in Leg. n. 24/2023 and that there is a consequential relationship between the report, disclosure or complaint made and the retaliatory measures suffered.

In addition to the protections offered by AT INTERNATIONAL S.r.l., there is – for individuals who have suffered or believe they have suffered retaliation as a consequence of a report, complaint or public disclosure – the possibility of reporting the retaliation to ANAC.

Specifically, the following individuals may make such a communication to ANAC’s address if they believe they have suffered retaliation as a result of a report, whistleblower or public disclosure: whistleblowers, facilitators, people in the same work environment, co-workers (including legal entities in cases where they are entities owned by the whistleblower), whistleblower, public discloser or entities in which they work or entities that operate in the same work environment.

In making the retaliation disclosure, it is necessary to acknowledge the consequentiality between the report, complaint or public disclosure made and the alleged retaliation. Thus, the whistleblower must provide ANAC with objective evidence from which it is possible to infer the consequentiality between the report, whistleblowing, public disclosure made and the complained of retaliation.

In such cases, upon receipt of the notice, ANAC carries out the investigations attributed to it by the law and, if it ascertains the retaliatory nature of acts, measures, behaviors, omissions adopted, or even only attempted or threatened, their nullity and the application of a pecuniary administrative sanction follows.

1. (d) Protection of the reported

AT INTERNATIONAL S.r.l. requires everyone to cooperate in maintaining a business climate of mutual respect and prohibits attitudes that may harm the dignity, honor and reputation of each person.

The confidentiality guarantees established by this Procedure also protect the reported person.

The reported person will not be disciplined in the absence of objective findings regarding the reported violation, i.e., without having investigated the reported facts and disputed the related charges by means of the legal and/or contractual procedures.

The whistleblower may not request to know the name of the whistleblower, except in cases expressly provided for by law. To further protect the reported person, the actions and faculties allowed to him or her by law remain unaffected.

8. DISCIPLINARY SANCTIONS AND OTHER MEASURES
   
   

AT INTERNATIONAL S.r.l. has set up a disciplinary system suitable for sanctioning its employees’ failure to comply with the rules of conduct and the requirements set forth in this procedure.

In particular, the Company shall adopt disciplinary sanctions against those who are responsible for any of the following relevant conduct, if the conditions are met:

• being responsible for one or more retaliatory measures provided for in Art. 17 of Legislative Decree. March 10, 2023 no. 24 or suggesting or proposing the adoption of any form of retaliation against the whistleblower;
• The obstruction of a report made pursuant to Leg. March 10, 2023 no. 24 or attempting to obstruct it;
• being responsible for a violation of the duty of confidentiality in the handling of reports;
• Failure to carry out the activity of verifying and analyzing the Reports received;
• having been guilty of the crimes of slander or defamation, ascertained by judgment, even if not final, committed with the complaint or report made, or having been held civilly liable, for having reported, in the reports or reports made, false information reported intentionally with malice or negligence.

The application of the sanctions in question is completely independent of the conduct and outcome of any criminal or administrative proceedings initiated by the judicial or administrative authorities, in the event that the conduct to be censured also counts as integrating any type of crime or administrative offence.

Disciplinary measures will be proportionate to the extent and seriousness of the established misconduct, may go as far as termination of employment for the most serious cases.

The greater or lesser seriousness of the violations will be evaluated on the basis of the following circumstances:

• The presence and intensity of the subjective element, in the form of intent or guilt;
• The presence and degree of intensity of negligence, recklessness, inexperience;
• the extent of the danger and/or consequences of the violation for the persons to whom the protections provided by this procedure and the whistleblowing regulations apply, as well as for the Company;
• The predictability of consequences;
• The timing and manner of the violation;
• The circumstances under which the violation took place;
• recidivism, consisting of the repeated imposition of disciplinary sanctions for violations of this procedure, as well as the repetition of disciplinary behavior, evaluated both in its episodic nature and overall (even if not sanctioned);
• The possible commission of multiple violations with the same conduct;
• The level of hierarchical and/or technical responsibility of the person to whom the charged conduct is referable;
• The possible sharing of responsibility with other parties competing in the violation of the procedure.

In any case, the sanction procedure is referred to the relevant corporate function and/or bodies.

1. (a) Disciplinary system for violations inherent in the reporting system

Compliance with the provisions and rules of conduct set forth in this procedure constitutes fulfillment by the Company’s employees of their obligations under Art. 2104, paragraph 2, c.c., of which the contents of this procedure are a substantial and integral part.

Therefore, conduct in violation of the provisions of this procedure by employees subject to the national collective bargaining agreement applied by the Company (CCNL Vetro) constitutes disciplinary offenses.

The commission of disciplinary offenses shall be sanctioned by the Company through the application of sanctions, in accordance with the procedures set forth in Article 7 of Law No. 300 (Workers’ Statute) and the provisions of the applicable collective bargaining agreement, particularly when imposing a sanction more serious than a verbal warning.

The disciplinary measures that can be imposed on these workers are, according to the seriousness of the infraction, those provided for in the following apparatus of sanctions:

• verbal warning;
• written recall;
• Fine in an amount not exceeding three hours’ pay;
• Suspension from salary and work for up to three days;
• Dismissal for punishment under 72 of the Glass Collective Bargaining Agreement.

The Company refers, for the regulation of relations with its employees, to the national collective bargaining agreement in force and applicable from time to time.

Disciplinary measures will be taken by the employer in relation to the extent of the misconduct and the accompanying circumstances, in full compliance with the principle of gradualness and proportionality between the offense committed and the sanction imposed, in accordance with the provisions of Paragraph 8 of this procedure and Article 7 of the Workers’ Statute.

In the case of recidivism, sanctions of the next higher grade than those applied for previous offenses may be applied.

Without prejudice to the prominence of other particularities of the concrete case, it will be considered a significant aggravating circumstance that the infraction resulted in the application by ANAC to the Company of an administrative pecuniary sanction under the relevant regulations.

In particular, with regard to violations of this reporting system, it is provided that, depending on the severity of the violation, assessed on the basis of the criteria and circumstances set forth in this paragraph 8:

• In case of retaliation:

• the employee other than the manager incurs the measure of suspension from duty and pay for up to three days or dismissal for punishment;
• the executive incurs the measure of suspension from service and pay for up to thirty days or dismissal for punishment;
• the director incurs the measure of suspension, with proportional loss of emoluments (where applicable), up to a maximum of ninety days, revocation of any proxies, and removal from office;

• In case of obstructing or attempting to obstruct the submission of reports:

• the employee other than the manager incurs the measure of suspension from duty and pay for up to three days or dismissal for punishment;
• the executive incurs the measure of suspension from service and pay for up to thirty days or dismissal for punishment;
• the director incurs the measure of suspension, with proportional loss of emoluments (where applicable), up to a maximum of ninety days, revocation of any proxies, and removal from office;

• in case of violation of the obligation of confidentiality of the identity of whistleblowers, whistleblowers, persons otherwise mentioned in the report and facilitators, as well as the content of reports and related documentation:

• the employee other than the manager incurs a fine, suspension from duty and pay up to a maximum of three days;
• the executive incurs the measure of suspension from duty and pay for up to ten days or dismissal for punishment;
• the director incurs the measure of a fine up to a maximum of 50% of the monthly emolument, suspension, with proportional loss of emoluments (where applicable), up to a maximum of thirty days, revocation of any proxies, and removal from office.

In addition, in all cases of breach of the duty of confidentiality-subject to the prominence of other particularities of the concrete case-the commissioning of the same by an employee or a manager assigned as the manager of the reports will be considered a significant aggravating factor;

• In case of failure to carry out the activity of verification and analysis of the reports received:

• the employee other than the manager incurs the measure of suspension from duty and pay for up to three days or dismissal for punishment;
• the executive incurs the measure of suspension from duty and pay for up to ten days or dismissal for punishment;

• In the case of unfounded reports, complaints or disclosures that are determined to have been made with malice or gross negligence:

• the employee other than the manager incurs the measure of suspension from duty and pay for up to three days or dismissal for punishment;
• the executive incurs the measure of dismissal for punishment;
• the director incurs the measure of revocation of any proxies and removal from office.

In addition, in all cases of unfounded reports, allegations or disclosures of which it is established that they were made with malice or gross negligence, the determination of damage to the Company will be considered the maximum aggravating factor.

In all the cases just listed, moreover, the Company reserves the right to claim compensation from the responsible party for the damage suffered by it as a result of the violation.

This procedure (or the relevant parts of it for the purposes of this paragraph 8) must be posted permanently in workplaces accessible to all, pursuant to and for the purposes of Article 7 of the Workers’ Statute.

An employee affected by a disciplinary measure who wishes to challenge the legality of the measure may also avail himself of the conciliation procedures provided for in Art. 7 of the Workers’ Statute or those stipulated in the collective bargaining agreements.

Regarding third parties (e.g., partners, suppliers, consultants, agents) AT INTERNATIONAL S.r.l. will sanction any illegitimate conduct by making use of the remedies and actions provided by law, as well as those provided by the contractual clauses.

9. PERSONAL DATA PROTECTION
   
   

The processing of personal data in the context of reporting will take place in compliance with applicable data protection legislation, including Regulation (EU) 2016/679 (“GDPR”), Legislative Decree. June 30, 2003 no. 196 and D. Lgs. May 18, 2018 no. 51, as well as any other applicable laws and/or regulations, and in accordance with the specific privacy policy (“Privacy Policy”) made to interested parties and published on the platform.

At the time of each report, the reported person and others involved in the report may not immediately receive privacy notices regarding the processing of their data, where there is a risk that providing such a notice would compromise the ability to effectively verify the merits of the report or gather the necessary feedback.

AT INTERNATIONAL S.r.l., in handling reports, operates in compliance with the applicable legal provisions, including, in particular, the principles of necessity, proportionality and lawfulness of processing as set forth in the GDPR. In accordance with the principle of minimization, set forth in Art. 5 GDPR, only personal data that are adequate, relevant and necessary in relation to the purposes of this Procedure may be processed. Therefore, all personal data (of the reporter, where the report is named, the reporter, the facilitator, and any other natural person) contained in the report or otherwise collected during the investigation phase that are not strictly necessary to ascertain and verify whether or not the Report is well-founded will be deleted or anonymized.

Data subjects may exercise, through the Platform, the rights recognized in Articles 15 to 22 of the GDPR in the cases and according to the limits provided by the GDPR itself. In any case, the Company may limit the exercise of the rights of data subjects by reason of the provisions of Art. 2-undecies of the Privacy Code or other applicable regulations. In addition, interested parties are informed of the right to exercise these rights through the Personal Data Protection Authority, in the manner set forth in Art. 160 of the Privacy Code.

Where there is a risk that actual and concrete prejudice to the confidentiality of the identity of the reporter may result from the exercise of the rights granted to the data subject and that the ability to effectively verify the merits of the report or to gather the necessary evidence may be jeopardized, AT INTERNATIONAL S.r.l. reserves the right to limit or delay the exercise of said rights, in accordance with the provisions of the laws in force

Under no circumstances may the whistleblower and/or third parties exercise their rights of access to obtain information on the identity of the whistleblower, except where the whistleblower has made a report that has proven, based on the concrete circumstances ascertained in the course of the investigation, to be not only unfounded on the basis of objective elements, but also made in bad faith or with gross negligence.

10. MORE INFORMATION – PROCEDURES, ASSUMPTIONS AND CHANNELS

TO CARRY OUT SO-CALLED “EXTERNAL REPORTING”

The National Anti-Corruption Authority (ANAC) has activated a service that allows a report to be made – regarding violations of national or European Union regulatory provisions that harm the public interest or the integrity of the public administration or the Company and/or the additional violations better described in paragraph 4 above, of which the reporting persons have become aware in the context of their own work context, public or private – through an external channel, which guarantees the confidentiality of the identity of the reporting person, the person involved and the person mentioned in the report, as well as the content of the report and the related documentation.

The same confidentiality is guaranteed even when the report is made through channels other than those provided for (and better described below) or reaches personnel other than those in charge of processing reports, to whom it is in any case transmitted without delay.

1. A) Prerequisites for external reporting

Access to this channel, however, is allowed only under certain conditions expressly stipulated by the legislature. Specifically, the reporting person may make an external report if at least one of the following conditions is met at the time of submission:

1. the internal reporting channel, although mandatory, is not active or, even if activated, does not comply with the requirements of Leg. n. 24/2023 with reference to the subjects and methods of internal reporting;
2. the reporting person has already made an internal report and it has not been followed up;
3. the reporting person has reasonable grounds to believe–based on the circumstances of the specific case, attached to the report, and information actually obtainable–that, if he or she made an internal report, the report would not be effectively followed up or that the report itself might result in the risk of retaliation;
4. the reporting person has reasonable grounds to believe that the violation may pose an imminent or obvious danger to the public interest.
5. B) External reporting channels

External reports can be made:

• in written form, through the IT platform made available by ANAC;
• orally, through the telephone lines or voice messaging systems specially set up by ANAC;
• At the request of the reporting person, through a face-to-face meeting set within a reasonable time.

An external report submitted to a person other than ANAC shall be forwarded to ANAC, within seven days from the date of its receipt, giving simultaneous notice of the transmission to the reporting person.

1. C) External reporting procedure

ANAC, has established a special Office for the Supervision of Whistleblowers’ Reports (UWHIB), consisting of staff specifically trained in the handling and processing of whistleblowers’ reports.

In addition, through the specifically trained staff of the UWHIB, it provides information on the use of the external reporting channel and the internal reporting channel, information requirements regarding the processing of personal data as well as protection measures under Chapter III of Leg. n. 24/2023.

When the reporting person has sent his or her external report through the channels referred to in subparagraph B above, within seven days from the date of its acquisition, the UWHIB shall give notice to the reporting person that the report has been received, unless the reporting person explicitly refuses or unless ANAC deems that the notice may prejudice the protection of the confidentiality of the reporting person’s identity.

The head of the UWHIB office shall first proceed to verify the existence of at least one of the conditions stipulated in subparagraph A above, and where none of the above conditions are met, the UWHIB shall dismiss the report as inadmissible. Otherwise, the Office proceeds to assess whether the eligibility requirements are met.

The report is considered inadmissible and is filed directly by the UWHIB office manager upon the occurrence of the following reasons:

1. manifest groundlessness due to the absence of factual elements attributable to the violations typified in Art. 2, co. 1(a) of Legislative Decree. n. 24/2023;
2. manifest absence of the legal prerequisites for the exercise of the Authority’s supervisory powers, including the absence of the prerequisites for making the report with particular reference to persons working in private sector entities;
3. manifest incompetence of the Authority on the reported issues;
4. ascertained generic content of the report of wrongdoing such that the facts cannot be understood, or report of wrongdoing accompanied by inappropriate or irrelevant documentation such that the very content of the report cannot be understood;
5. Production of only documentation in the absence of reporting misconduct;
6. Lack of data that constitute essential elements of the reporting of wrongdoing indicated by the Regulations for the Handling of Reports and the Exercise of Sanctioning Power;
7. Existence of minor violations.

In the cases referred to in (d) and (f), the UWHIB, where what is reported is not adequately substantiated, may request additional elements from the whistleblower through the dedicated channel.

The UWHIB maintains interlocutions with the reporting person, keeping track of the activity carried out and providing information, including ex officio, on the progress of the investigation, at least with reference to the main decision-making hubs.

The UWHIB properly follows up on the reports received through the following activities:

1. outside the cases of inadmissibility, the UWHIB forwards the report of wrongdoing to the relevant supervisory offices. They carry out investigative activities in accordance with the relevant Supervisory Regulations and the guidelines adopted by the Authority in this regard;
2. if the report relates to offenses that are relevant from a criminal or erarial point of view, the UWHIB files the same because it is inadmissible due to manifest incompetence of the ANAC and arranges for its immediate transmission, with a note signed by the President of the Authority, to the competent judicial or accounting authority, pointing out that it is a whistleblowing report, in the process of management of which, therefore, every precaution must be taken to ensure compliance with the provisions of the regulations;
3. if the report of wrongdoing relates to violations that do not fall within the objective scope of ANAC’s intervention, but rather within the competence of another administrative authority or an institution, body, or organ of the European Union, the UWHIB orders it to be filed because it is inadmissible and forwarded for possible follow-ups within its competence, taking care to indicate that it is a whistleblowing report and that therefore all necessary precautions must be taken in terms of confidentiality protection and processing of personal data.

In any case, the UWHIB shall provide feedback to the reporting person within three months or, if there are justified and substantiated reasons, six months from the date of notice of receipt of the external report or, in the absence of such notice, from the expiration of seven days from receipt.

In other words, the UWHIB within three to six months notifies the reporter:

• The direct filing prepared or intended to be prepared;
• The transmission to the competent authority already made or intended to be made;
• the work already carried out by the competent supervisory office within the Authority or that the latter intends to carry out.

Subsequently, where in the above time frame the UWHIB has not communicated a final determination on the follow-up of the report but only the activities that are intended to be undertaken, the UWHIB shall notify the reporting person of the final outcome of the handling of the report, which may consist of direct filing, investigative findings of the competent supervisory office, or transmission to the competent authorities.

11. PUBLIC DISCLOSURE
    
    

In cases where the report relates to violations of the European Union rules referred to in the letters (a) and (b) of Paragraph 4 above “Subject of Reporting” and when one of the following conditions is met:

–                   the reporter has previously made a report through internal channels and external channels, or made an external report directly, and in all these cases no response was given within the stipulated time;

–                   the reporter has reasonable grounds for believing–based on the particular circumstances of the case, which are serious, precise, and concordant–that the violation may constitute an imminent or obvious danger to the public interest (e.g., an emergency situation or there is a risk of irreversible harm, including to the physical safety of one or more persons, requiring that the violation be promptly disclosed and have a wide resonance to prevent its effects);

–                   the reporter has reasonable grounds for believing – based on the particular circumstances of the case, which are serious, precise and concordant – that the external report may involve the risk of retaliation or may not be effectively followed up due to the specific circumstances of the concrete case, such as those where evidence may be concealed or destroyed or where there is a well-founded fear that the recipient of the report may be colluding with or involved in the violator;

the reporter may make a public disclosure, through print or electronic media or means of dissemination capable of reaching a large number of people.

12. REPORT TO THE JUDICIAL AUTHORITY
    
    

The Decree also recognizes the possibility for protected individuals to turn to the Judicial Authorities, to file a complaint of unlawful conduct they have become aware of within their work context.