Whistleblowing Procedure

FREZZA S.R.L., recognizing the importance of establishing appropriate reporting channels to safeguard the Company’s integrity and ensure adherence to the principles of legality, fairness, and transparency, including towards third parties in the course of business activities, has activated specific internal reporting channels in compliance with Legislative Decree No. 24/2023, implementing EU Directive 2019/1937.

Through this Notice, FREZZA S.R.L. aims to widely disseminate information to all Recipients regarding the channels, procedures, and prerequisites for making both internal and external reports.

WHO CAN MAKE A REPORT

The following individuals operating in the company’s work environment are authorized to report:

employees;
freelancers and collaborators performing their work at the Company;
professionals and consultants providing services to the Company;
volunteers and interns, whether paid or unpaid, working with the Company;
individuals with administrative, managerial, supervisory, control, or representation functions, including those exercising such functions in practice within the Company.

Reports can be made even when a legal relationship has not yet commenced, if information regarding violations was acquired during the selection process, pre-contractual phases, probationary period, or after the end of the legal relationship, provided the information was obtained during the relationship.

WHAT BEHAVIORS CAN BE REPORTED

Relevant Reports include reports regarding behaviors, acts, or omissions that harm the public interest or the Company’s integrity, which the whistleblower becomes aware of in the work context, including:

unlawful conduct relevant under Legislative Decree No. 231/2001 and violations of Model 231, such as, for example, corrupt practices toward Public Administration, breaches of Health and Safety regulations, and violations of Environmental regulations. These reports can only be made through internal reporting channels;
illegal activities falling within the scope of EU acts related to the following sectors: public procurement; financial services, products and markets, and prevention of money laundering and terrorism financing; product safety and compliance; transport safety; environmental protection; consumer protection; privacy and data protection; network and information system security;
acts or omissions that damage the European Union’s financial interests, such as fraud, corruption, and any other illegal activity related to EU spending;
acts or omissions concerning the internal market, including breaches of EU competition rules, State aid regulations, corporate tax rules, free movement of goods, people, services, and capital;
acts or conduct that undermine the purpose or objectives of the provisions in the EU acts mentioned above, such as, for example, abusive practices contravening competition protection (e.g., predatory pricing, target discounts, tying sales, etc.).

Reports related solely to the whistleblower’s personal interest, such as individual employment matters or issues with superiors, or concerning the private life of the reported person without any direct or indirect link to company or professional activities, are excluded from the scope of this policy.

Also excluded are baseless rumors, publicly available information, hearsay, or speculative, slanderous, or defamatory information intended solely to damage the reported party.

These “excluded reports” are therefore not considered whistleblowing reports. The company may decide within its internal regulations if and how to handle this type of report.

CHARACTERISTICS OF THE REPORT

To enable an adequate verification process, the report must be as detailed as possible to allow reconstruction of the facts and assessment of the validity of the report. Specifically, the report should include:

The whistleblower’s identifying information (name, surname, place, and date of birth) and, in the case of a postal, phone, or direct meeting report, contact details to receive acknowledgment of receipt and follow-up requests for further information or clarifications;
the time and place where the reported event occurred, along with a description of the facts, including relevant details and how the information was obtained;
the identities or other identifiers of individuals involved in the reported facts;
any attached documents;
potential witnesses to the facts.

Anonymous reports, if sufficiently detailed and supported by appropriate documentation, will be processed as regular reports following the internal procedures established for whistleblowing.

INTERNAL REPORTING CHANNELS

To allow written and oral reports, the Company, in consultation with union representatives or organizations, has activated and maintains the following reporting channels:

Written reporting channel:
- Regular mail address: Frezza S.r.l., Via Ferret 11/9, 31020 Vidor (TV); the whistleblower must place the report in two sealed envelopes, with the first containing their identification and an ID document, and the second containing the subject of the report. Both envelopes should then be placed in a third envelope marked “Whistleblowing Report” or “Confidential to Channel Manager.”
Oral reporting channel:
- a phone line available Monday to Friday from 8:30 am to 12:30 pm and from 2:00 pm to 6:00 pm, at 0423/987800, forwarded to the Channel Manager. To ensure confidentiality, the whistleblower must immediately indicate they intend to make a “Whistleblowing Report.”

If requested, a direct meeting with the Channel Manager can be arranged. The meeting will be conducted privately by the Channel Manager, and a report form will be prepared.

Frezza S.r.l., in full compliance with the Whistleblowing Decree, guarantees that these channels maintain the confidentiality of the whistleblower’s identity, the identity of the individuals involved, and anyone mentioned in the report, as well as the content of the report and its documentation.

The Channel Manager is the Whistleblowing Committee, composed of Ms. Stefania Polini (HR Manager) and Mr. Nico Lucchetta (Quality, Customer/Supplier, ESG Certification Manager).

If a member of the Whistleblowing Committee has a conflict of interest as the whistleblower, reported person, or involved party, they will abstain from all activities, and the report will be managed by the other non-conflicted member. If both members are conflicted, they will issue an acknowledgment of receipt and promptly refer the report to the ODV function, abstaining from any further actions.

REPORT MANAGEMENT PROCEDURES

Upon receiving a report, the Channel Manager will:

issue an acknowledgment of receipt within seven days;
maintain communication with the whistleblower and, if necessary, request additional information;
diligently follow up on reports, engaging appointed personnel for management, such as the ODV for matters related to Model 231;
provide feedback to the whistleblower within three months of the acknowledgment or, if not acknowledged, within three months of the seven-day acknowledgment deadline. This feedback may be interim if the investigation is still ongoing. Once concluded, the outcomes will be communicated to the whistleblower.

Qualified internal or external personnel, free of conflicts of interest and bound by confidentiality obligations, may be involved as necessary for report handling.

If the report is substantiated, the Channel Manager will contact internal bodies/functions to initiate preventive, corrective, or disciplinary actions against the reported party.

EXTERNAL REPORTING CHANNEL (ANAC)

Certain conditions must be met to use the reporting channel established by ANAC. Specifically, the whistleblower can proceed with an external report only if: the internal reporting channel in their workplace is not active or non-compliant with Legislative Decree No. 24/2023; they have already made an internal report without follow-up; they have reasonable grounds to believe that an internal report would be ineffective or could result in retaliation; or they reasonably believe that the violation constitutes an imminent or clear danger to the public interest. Any retaliation suffered may also be reported through this channel.

See https://www.anticorruzione.it/-/whistleblowing

Data will be processed in accordance with GDPR No. 679/2016 and Legislative Decree No. 24/2023.

See Whistleblowing Privacy Policy.