Updated in line with the specific Guidelines on whistleblowing, approved by ANAC Resolution No. 478 of 26 November 2025

Nessi & Majocchi S.p.A. has adopted an internal reporting channel (so-called “whistleblowing”) pursuant to Legislative Decree of 10 March 2023, No. 24 (implementation of Directive (EU) 2019/1937), to enable the confidential and protected reporting of violations and unlawful acts identified within the work-related context.

Who can make a report
• employees (including probationary employees), former employees and individuals in the selection phase/pre-contractual negotiations;
• self-employed workers, consultants, collaborators/contractors, trainees/interns (paid or unpaid), volunteers;
• shareholders, and persons with administrative, management, control, supervisory or representative functions;
• suppliers, contractors, subcontractors and persons working under their supervision.

What can be reported
• breaches of national or European Union legal provisions falling within the scope of Legislative Decree 24/2023;
• unlawful conduct relevant pursuant to Legislative Decree 231/2001 and breaches of the 231 Model (where adopted), the Code of Ethics and/or company procedures, when connected to violations/unlawful acts in the work-related context;
• attempts to conceal such violations.

What is not covered by the whistleblowing channel
Complaints, claims or requests related to a personal interest of the reporting person that relate exclusively to their employment relationship (e.g., individual disputes), unless they constitute violations/unlawful acts falling within the scope of Legislative Decree 24/2023.

Mailbox Details

WHISTLEBLOWING MANAGER
Ufficio Postale Via Tolomeo Gallio, 6
Casella Postale 124
22100 Como (CO)

Written report (post)
Sending by post in a closed and sealed envelope, using the “double-envelope” method (recommended to ensure confidentiality):
• Outer envelope: write “CONFIDENTIAL – PERSONAL – WHISTLEBLOWING” and the addressee “Whistleblowing Manager”;
• Inner envelope no. 1 (optional): identifying details and a contact address for communications (e-mail/post/telephone) – kept separate from the content of the report;
• Inner envelope no. 2: description of the facts and any attachments/documents.

Oral report
• At the request of the reporting person, an oral report may be made through a face-to-face meeting with the Whistleblowing Manager.
• The request may be sent using the same methods as the written report (stating that a meeting is requested).
• The meeting is scheduled within a reasonable time and is conducted in a manner suitable to ensure confidentiality.
• If agreed, the oral report may be documented by means of an audio recording or minutes; the recording requires the reporter’s consent.

Anonymous reports
Anonymous reports are also allowed. Where an anonymous report is detailed and supported by useful elements, Nessi & Majocchi S.p.A. will handle it in accordance with this procedure. To enable the response timeframes required by law (acknowledgement of receipt and feedback), it is recommended to provide at least one contact method that does not necessarily reveal identity (e.g., a dedicated e-mail account used by the reporter). If no contact is provided, it will not be possible to send communications.

Handling timeframes
• Acknowledgement of receipt: within 7 days of receipt (if a contact method is available).
• Follow-up: the Whistleblowing Manager may request additional information or clarification.
• Feedback: within 3 months of the acknowledgement of receipt or, if none, within 3 months of the expiry of the 7-day period.

Confidentiality and protections
The confidentiality of the reporter’s identity, of the persons involved and of the content of the report is guaranteed. The reporter’s identity may not be disclosed without their express consent, except where required by law and in cases where such knowledge is indispensable for the defence of the person concerned, as provided for by Legislative Decree 24/2023.
Nessi & Majocchi S.p.A. prohibits any form of retaliation, direct or indirect, against the reporter and the individuals protected by the applicable legislation. Liability remains in place in the event of reports made with intent or gross negligence (e.g., slander/defamation), ascertained by the competent authorities.

External reporting and public disclosure
It is always possible, in the cases and under the conditions set out in Legislative Decree 24/2023, to submit an external report to ANAC and, where the legal requirements are met, to make a public disclosure.

Privacy notice (excerpt)
Data Controller: Nessi & Majocchi S.p.A., Registered office: Via Regina Teodolinda 49/a, 22100 Como (CO). The data are processed by authorised personnel and, where necessary, by external parties bound by specific obligations (e.g., consultants). Retention period: for the time necessary and in any event no longer than 5 years from the closure of the proceedings. For information and to exercise privacy rights: DPO Avv. Alessandro Ronchi – privacy@nessimajocchi.it.

Last update: 30th January 2026