1. Scope
This Procedure governs the management ofreports (“Reports”) for potential violations of the Code of Conduct, Marcolin Group’s policy or applicable laws and regulations, including LegislativeDecree 231/2001 and the Organization and Management Model of Marcolin S.p.A. that could cause prejudice to Marcolin Group. Marcolin Group has adopted this “whistleblowing” procedure in order to provide a clear and confidential reporting channel of information to those subject to Code of Conduct and the Organization and Management Model who collaborate or come into contact with the Marcolin Group at all levels. Marcolin Group commits to safeguarding the anonymity of the reporting person and to protecting him/her against any form of retaliation or discrimination. Penalties shall be imposed on any person who violates the protection measures of the reporting person.The application of these regulations is limited to cases of the reporting person who acts in good faith. Therefore, on the basis of the applicable disciplinary procedure, whoever acts out of will fulm is conduct or gross negligence will be subject to sanctions. Moreover, anonymous reports will not be considered. The Procedure applies to all Marcolin Group’s companies.
2. Reporting channels
The Report can be issued by letter or e-mail, duly signed, to one of the following addresses:-marcolin.integrity@legalmail.it -Comitato Etico -Marcolin S.p.A. –Zona Industriale Villanova 4 Longarone (BL). Both the above-mentioned reporting channels guarantee the confidentiality of the reporting person. The Reports need to be detailed and include precise and substantially complete details relating to the violation reported. Therefore, information such as relevant subject matter, place, time and facts need to be included.
3. Internal procedure for the handling of the report
The Company has established an Ethics Committee composed of 3 members (HR Director, Legal Counsel and President of the Surveillance Body) which has the task of examining all the reports received.
Once the report is received, the Ethics Committee of Marcolin Group will verify the non-anonymity and the adequacy of details (the report needs to include subject, place, time and facts).If the report concerns possible violations of the Organization and Management Model ex Legislative Decree 231/2001 applicable by Marcolin S.p.A., the Surveillance Body will be informed and involved in the process too. In order to start the essential checks, the Ethics Committee can, at its full. discretion, use any company function considered suitable to give support based on their professionalism and/or relevant knowledge.The investigation will take place in line with applicable regulations, with respect for the rights of the subjects involved. The Ethics Committee will examine the validity of the report through any activity it considers worthwhile, including the personal hearing of the reporting person and/or potential other subjects who could report on the event, with respect for the principles of impartiality and confidentiality. The Ethics Committee can suspend or interrupt the investigation at any moment should the subject matter of the report be found to be baseless. In the event that a reporting person is found to have acted with will fulm is conduct or gross negligence, the Ethics Committee will reserve its right to propose the relevant corporate bodies the start of a disciplinary action towards the reporting person. At the conclusion of an investigation, where a violation in question has been verified, with respect for the essential confidentiality criteria, the results will be transmitted to the corporate body in charge of potential actions that might need to be taken, potentially including disciplinary action. The filing of all the documents concerning the reports and the following investigation will occur at the legal office group at Marcolin S.p.A., through reporting channels suitable to ensure the respect of confidentiality and anonymity principles. For any clarification about the procedure in question you can contact the Ethics Committee of the Marcolin Group at the above-mentioned addresses