WHISTLEBLOWING POLICY
Coipa Italia S.p.A.

1. Introduction
Coipa Italia S.p.A. is firmly committed to the highest standards of ethics, integrity, and transparency in all aspects of its operations. This Whistleblowing Policy establishes a secure, confidential, and accessible process for reporting suspected misconduct, unethical behavior, or legal violations, without fear of retaliation.

2. Purpose
The purpose of this policy is to foster a culture of accountability by:

• Encouraging the reporting of suspected wrongdoing.

• Ensuring timely and thorough investigation of reported concerns.

• Protecting whistleblowers from retaliation.

• Promoting compliance with applicable laws, regulations, and internal policies.

3. Scope of Reportable Concerns
Employees, contractors, suppliers, and stakeholders are encouraged to report concerns such as:

• Fraud, bribery, corruption, or financial misconduct.

• Violations of laws or regulations (e.g., health and safety, labor, environmental, data protection).

• Conflicts of interest.

• Misuse of company assets or resources.

• Discrimination, harassment, or workplace misconduct.

• Breaches of internal policies and codes of conduct.

4. Reporting Channels
Coipa Italia S.p.A. provides several confidential reporting options:

• Internal Reporting Tool: A secure system (email, hotline, or dedicated intranet page) is available to report concerns directly to the Compliance or HR Department.

• Anonymous Platform: An external third-party platform may be used to submit reports anonymously, while maintaining full data protection.

• Direct Reporting: Concerns may also be raised with a line manager, the Compliance Officer, or the Legal Department, unless they are involved in the alleged misconduct.

5. Protection of Whistleblowers
Coipa Italia S.p.A. ensures that all whistleblowers who act in good faith are protected from retaliation, including:

• Confidentiality: Reports will be treated with the strictest confidentiality, and whistleblower identity will only be disclosed when legally required.

• Non-Retaliation: Any form of retaliation, intimidation, or unfair treatment is strictly prohibited and may result in disciplinary action.

• Anonymity: Reports may be submitted anonymously. While this may limit communication, all reports will be reviewed with equal diligence.

6. Investigation Process
Upon receiving a report, the following steps will be followed:

1. Acknowledgement: Confirmation of receipt (if not anonymous).

2. Assessment: Preliminary evaluation of the nature and severity of the report.

3. Investigation: A formal inquiry may be conducted, including interviews and document review.

4. Outcome: Appropriate corrective measures will be taken, and disciplinary or legal actions pursued when necessary.

5. Feedback: If possible, the whistleblower will be informed of the investigation outcome.

7. False or Malicious Reports
Reports made in bad faith, with the intent to harm or mislead, are not tolerated and may lead to disciplinary measures.

8. Awareness and Training
Coipa Italia S.p.A. promotes awareness through:

• Regular training sessions on whistleblower rights and procedures.

• Easy access to the policy on internal platforms.

• Mandatory inclusion in onboarding programs.

9. Compliance with Applicable Laws
This policy aligns with relevant EU and national legislation, including Whistleblower Protection Laws, Anti-Corruption Laws, and Data Protection Regulations (e.g., GDPR).

10. Policy Review and Improvement
The policy is reviewed periodically to ensure effectiveness and compliance. Feedback from stakeholders is encouraged to support continuous improvement.

11. Conclusion
This Whistleblowing Policy is a fundamental part of Coipa Italia S.p.A.’s ethical framework. We encourage all individuals to report concerns confidently, contributing to a responsible, compliant, and transparent organizational culture.