Whistleblowing

AEM Italia Srl

ORGANIZATION, MANAGEMENT, AND CONTROL MODEL
PURSUANT TO LEGISLATIVE DECREE JUNE 8, 2001, NO. 231

WHISTLEBLOWING

Procedure for reporting unlawful acts and irregularities

As of December 17, 2023, AEM has implemented a management model for reporting unlawful acts and irregularities in compliance with Legislative Decree 231/2001 and its subsequent amendments.

The reporting procedure applies to all company employees, collaborators, and anyone who has professional or business relations with AEM srl.

The model is available on the company’s server and/or website and can be submitted to the Supervisory Body (ODV), appointed under Legislative Decree 231/2001, via the email:
segnalazioniodv@aemitalia.com
accessible to all concerned parties.

As outlined in Decree 24/2023, reportable offenses include, among others:

• • Administrative, accounting, civil, or criminal offenses;

• • Unlawful conduct relevant under Legislative Decree June 8, 2001, No. 231, or violations of the organization and management models established therein;

• • Offenses related to the following sectors: public procurement, financial services, products, and markets, anti-money laundering and counter-terrorism financing, product safety and compliance, transport safety, environmental protection, radiation protection and nuclear safety, food and feed safety, animal health and welfare, public health, consumer protection, privacy and personal data protection, network and information system security;

Consequently, those who identify or become aware of potential unlawful behavior or irregularities in work activities carried out by individuals with professional relations with AEM are required to report the facts, events, and circumstances that they believe, in good faith and based on reasonable elements, have led to such violations or conduct that does not comply with the provisions of Organizational Model 231.

To this end, the report must include the following elements:

1. 1. the identity of the reporting individual, including their role within the company (unless the report is submitted anonymously);

1. 1. a description of the reported facts;

1. 1. the time and place where the events occurred, if known;

1. 1. the identity or any useful elements for identifying the perpetrator(s) of the reported facts;

1. 1. the names of any other individuals who may provide information on the reported events;

1. 1. any supporting documents that may confirm the validity of the reported facts;

1. 1. a statement indicating that the report is made with the intention of maintaining confidentiality and benefiting from the protections provided in case of possible retaliation.

It should be emphasized that this Model does not concern personal grievances, claims, or requests related to the employment relationship or issues with a superior, which should be addressed solely through the applicable employment regulations.

If, following an investigation, the report is found to be valid, the designated company representative will inform AEM’s Management, which will decide:

(a) the appropriate actions to be taken if necessary to protect the Company;

(b) whether to file a report with the competent Judicial Authority;

(c) whether to communicate the outcome of the investigation to the Head of the Function to which the perpetrator of the confirmed violation belongs, so that the necessary measures, including disciplinary actions, can be taken.

AEM ensures adequate protection of the whistleblower’s identity, strictly condemning any conduct that violates the protective measures in place, including through appropriate IT safeguards and other measures to protect confidentiality.

No form of retaliation or discriminatory action, direct or indirect, affecting working conditions will be permitted or tolerated against the whistleblower for reasons directly or indirectly related to the report.

Download the reporting model here

Genoa, 17.12.2023 rev.0