Whistleblowing – Reports

The Company, in accordance with the relevant regulations, provides an online platform
(Whistleblowing Portal) that can be freely accessed by those who wish to make, in good faith, reports of unlawful conduct, commission or omission.

Such reports are also accepted anonymously.
The Company will prosecute the authors of reports made in bad faith, with defamatory intent or that are not in the proper spirit of cooperation towards the company.
Reports must be made in order to protect the integrity of the Company and must be detailed, that is, based on precise and concordant facts.

Reports must be made in a spirit of responsibility, be of interest to the common good, and fall within the types of non conformities for which the system has been implemented.
The Company invites not to make reports that do not fall within the above cases and, as a general rule, encourage its employees to resolve any labor disputes, where possible, through dialogue, even informally, with their colleagues and/or with their direct supervisor or with the relevant Company Functions.

METHOD OF SUBMISSION AND RECIPIENTS OF THE REPORT

Reports can be sent:

• verbally by conferring with one of the members of the Management Committee by e-mail, to the reference address of the Management Committee Mi-MeWB@Mi­Me.it;
• through the use of the online Whistleblowing Portal made available by the Company, which provides a guided path for the Whistleblower; the Whistleblowing Portal can be reached on the Mi-Me website.

lt should be noted that the Whistleblowing Portal is the mode that can fully guarantee the possible anonymity of the Whistleblower.

Access to the Whistleblowing Portal is subject to the “no-log” policy in order to prevent the identification of the Whistleblower who intends to remain anonymous: this means that the company’s IT systems are not able to identify the portal access point (IP address) even in the event that access is made from a computer connected to the company network.

For each Report entered, the Portal assigns a unique identification code that allows each Reporter to check its progress, completely anonymously.

Similarly, in the event that a Report is inadequately substantiated, the recipient, making use of the Portal and its related instrumentation, will have the right to request from the Reporting Party, again and only by means of that code, further elements of detail, for the purpose of an in-depth analysis of the reported case.

The Reports made through the Whistleblowing Portal are received directly by the Mi-Me Management Committee, which handles the same in compliance with the principles of confidentiality set forth in the Whistleblowing Policy adopted by the Company and verifies their validity in accordance with the procedures set forth therein.

PROTECTION AND RESPONSIBILITY OF THE REPORTER

No retaliation or discrimination, direct or indirect, may result in the person who has made a Whistleblowing in good faith.
In the case of reports made through the Whistleblowing Portal, the anonymity of the Whistleblower is guaranteed, except in cases where the Whistleblower expresses consent to disclosure and subject to legal obligations. In addition, sanctions are provided against those who violate the Whistleblower’s protection measures.
Penalties are provided against the Whistleblower, where possible, in the case of reports made with fraud or serious negligence that turn out to be false and unfounded, with defamatory content, or otherwise made for the sole purpose of damaging the Company, the Whistleblower, or persons affected by the Report. The Company may also take appropriate legal action.

PROTECTION OF THE REPORTED PERSON

During the activity of verifying and ascertaining possible non-compliance, the individuals who are the subject of the Reports may be involved in or notified of this activity, but under no circumstances will a proceeding be initiated solely on the grounds of the Report, in the absence of concrete findings regarding the content of the Report. This could possibly be done on the basis of other evidence found and ascertained from the Report itself.

PRIVACY

Any personal or sensitive data contained in Reports, including those relating to the identity of the Reporting Party or other individuals, will be processed in accordance with applicable data protection legislation.