Everyone has the right to submit a report to the Supervisory Body: employees, collaborators, partners of the company, but also third parties with whom it relates, including, by way of example, customers and suppliers.

The behaviours to be reported may consist, for example, of
• administrative, accounting, civil or criminal offences;
• relevant unlawful conduct pursuant to Italian Legislative Decree 231/2001, or violations of the Organisation, Management and Control Model adopted by the company;
• offences falling within the scope of EU or national acts relating to the following areas: public procurement; financial services, products and markets and the prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; protection of privacy and protection of personal data and security of networks and information systems;
• actions or omissions affecting the financial interests of the European Union;
• actions or omissions regarding the internal market;
• acts or conduct which undermine the subject or purpose of the provisions of EU acts.
In addition to the aforementioned violations, it should be noted that it is possible and even useful and desirable to also report behaviours that can also generate the simple risk of committing them, or the mere attempt to put them in place, so as to be able to intervene in advance, that is, before any offenses are committed.

Novellini Group has identified the Supervisory Body as the recipient of the reports received through the channel, in particular as a subject external to the company and totally independent. The Supervisory Body undertakes to ensure the secrecy of the identity of the whistleblower, without prejudice to the obligations and provisions of the law on the matter. All parties concerned (workers, suppliers, customers, business partners, etc.) can contact this subject to report any illegal, risky or non-compliant behaviour or other irregularities that may have been detected. In addition to the reporting channel available at present.

Knowing that any reports can provide a useful and constructive contribution to the implementation and improvement of its organization, the company undertakes to protect those who report any irregularities or malfunctions, protecting them from possible retaliation. Whistleblower protection is an integral part of company policies for compliance with the principles of legality and transparency that inspire the company.

To make a report, you can use the channel reachable at the following link:
https://novellinispa.signalact-inaz.it/whistleblowing or even directly via the web at the same address.
The site does not track users' browsing data; however, please note that it is always possible to activate incognito browsing using specific browsers that protect anonymity (for example, Tor Browser).
The other communication channels with the Supervisory and Reporting Body already made available by the company at the time for the purpose of the adoption of the Organisation, Management and Control Model remain unaffected, in particular:

- by post, in a closed envelope bearing the words “RESERVED” addressed to the attention of the Supervisory Body of the Company concerned by the report and sent by post to the address Via Mantova no. 1023, (46030) Borgo Virgilio – Fraz. Romanore (MN) or inserted personally in the relevant box located at the same premises. If the whistleblower intends to ensure a reinforced level of protection regarding his/her identity, he/she is invited to insert the report in two closed envelopes, including, in the first, the identification data of the whistleblower and, in the second, the text of the report or any other means for its transmission (e.g. CD or other support in the event of voice recording); both envelopes must then be inserted in a third envelope addressed to the address referred to above;

- requesting a direct interview with the manager of Whistleblowing or with the Supervisory Body, by making the request by means of a message to be transmitted through the https://novellinispa.signalact-inaz.it/whistleblowing portal;

- by contacting directly the Chairman of the Supervisory Board, external to the organization of the Company Mr. Salvatore Vittorio Castelli, Via Perosi no. 54, 20862 Arcore (MB)

For communications regarding which there are no particular needs for protection or confidentiality of your identity, you can also write to the entire Board of Supervisory Body at odv231@novellini.it.

To support whistleblowers who do not intend to use the electronic reporting channel on the page https://novellinispa.signalact-inaz.it/whistleblowing, which in any event you are invited to use as the main channel for the management of reports, you can optionally use also the form downloadable below.

We inform you that, in order to ensure an effective and efficient development of the organisational structure and the risk control measures that are part of it, the subject of reporting cannot be disciplinarily sanctioned in any way based on the mere statement of the whistleblower, without there being objective findings and without adequate investigation of the facts subject to reporting.
Any reports made in bad faith, in an opportunistic manner, as well as unfounded for wilful misconduct or gross negligence, are also a source of liability in disciplinary proceedings and at other appropriate levels.
The protections provided for by the legislation to protect whistleblowers are not guaranteed when the conditions provided for by law are not met (absence of well-founded reason to believe that the information on the violations reported was true and fell within the objective scope of application of Italian Legislative Decree no. 24/2023 and that the report was made based on the provisions of the Decree) or when the reporting person's criminal liability for the offences of defamation or slander or his/her civil liability, for the same reason, in the event of wilful misconduct or gross negligence is established, even by a judgment of first instance.

Personal data are processed by the Novellini Group companies (Novellini Industries S.r.l., NovALmec S.r.l. and Novellini S.p.a.), each identified, depending on the company to which the report refers, as the data controller, in accordance with current legislation (Regulation (EU) 2016/679, Italian Legislative Decree 196/2003 and Italian Legislative Decree 51/2018). Any personal data that are clearly not relevant to the processing of a particular report are not collected or, if collected accidentally, are immediately erased. The rights referred to in Articles 15 to 22 of Regulation (EU) 2016/679 may be exercised within the limits of the provisions of Article 2-undecies of Italian Legislative Decree no. 196 of 30 June 2003. The internal and external reports and the relevant documentation are kept for the time necessary for the processing of the report and, in any event, for no more than 5 years as of the date of communication of the final outcome of the reporting procedure, in compliance with the confidentiality obligations set out in European and national legislation on the protection of personal data. For details regarding the processing of personal data, please consult the complete information available below and also submitted directly in the report management channel.

Below is the whistleblowing procedure that illustrates the reporting management process adopted by Novellini