WHISTLEBLOWING

Whistleblowing is a tool that allows employees or third parties (for instance, suppliers) to privately report any wrongdoing or misconduct identified in their work activities.

The whistleblower is the person who identifies any wrongdoing or unlawful situation at work in the fulfilment of their professional duties and decides to report it to the Company, the entity they belong to or a public authority who can take appropriate action on the matter.

The whistleblower is protected by the law. For any additional information, please read the relevant provisions on whistleblowing (Normativa WhistleBlowing, Italian Law No. 179/2017 - Legislative Decree No. 24/2023) available on the Internet.

The Company has in place two possible reporting systems:

• via its online platform: reporting on the platform may take place in writing or through voice messages. User registration is possible, but not required. This reporting channel preserves the confidentiality of the source and of the information being reported, pursuant to the applicable law. Click on "Segnalazioni" (Reporting) to access the platform.

• by traditional mail at the address Via Leonida Repaci, n. 16, Viareggio (LU).
  The envelope shall be marked: “RISERVATA AL GESTORE DELLA SEGNALAZIONE” (CARE OF THE REPORTING MANAGER).

There is no pre-fixed list of the types of wrongdoing, misconduct or unlawful situations that may be reported through whistleblowing. Relevant information includes any behaviours, risks, crimes or unlawful situations that may affect public interest.

Whistleblowing does not include personal complaints by the reporter, which are normally regulated by different procedures.

The reporting form includes a series of topics. Please choose from among them. For additional information, please read the relevant policies.

Any misconduct/wrongdoing reported should be related to situations that the reporter has learnt about directly or indirectly, including by chance, as a result of their working relationship with the Company and/or the position held.

Any reports based on suspicion or gossip do not entitle the reporter to protection, since the interests of the third parties subject of the whistleblowing must be taken into consideration, while also preventing any useless and expensive internal investigations by the Company or entity receiving the report.

All the above without prejudice to the requirement of truthfulness, so as to ensure protection of the person(s) being reported.

The report shall only be accessible to you and to Overmarine Group Spa's Whistleblowing Manager. This platform allows you to report in a secure and confidential manner. If provided for by the applicable Regulations, you may report anonymously.

Confidential Reporting: 'Confidential Reporting' means that the Whistleblower can be identified. Confidential reporting requires prior registration by the user. Once an account has been created, the user may submit their report. Confidential reporting is also possible without registration, by completing the reporting form in the section "Segnala senza registrazione" (Report without registering) - if present - and including your personal data in the final section of the form. The Reporter's details will remain separate from the report, so the Confidential Report will be submitted to the Manager anonymously. Only the Manager will be able to associate a report to the Reporter's details and display the Reporter's identity.

Anonymous Reporting: in anonymous reporting, the report cannot be associated with the name of the Reporter, as no Reporter details are provided. In this case, the Reporter is not required to register in the system and may submit their report as a non-registered user in the section "Segnala senza registrazione" (Report without registering), if present.

This platform guarantees information security and confidentiality. All the content you enter, including your personal data, is encrypted and can only be read by you and by the recipient(s) of your report (Whistleblowing Manager).

Once the report has been submitted, you can trace it and keep communicating with the Whistleblowing Manager through the report messaging section. In this case too, all information is encrypted and secured by the platform. If you have entered an e-mail address (or you have registered), when the Whistleblowing Manager messages you, you will be notified by e-mail. In any case, we recommend that you periodically access your report to check for any requests for clarifications by the Manager. For additional confidentiality, we recommend you do not use a Company e-mail address.

If you have given your name or if you submit your report as a registered user, your identity will remain hidden to the Manager too, who will however be able to display it if deemed necessary. Should that be the case, you will receive a notification within the report itself.

For additional confidentiality, we recommend the following:

• do not include in your report any personal information that may make it possible to trace back your identity;
• when you register or provide an e-mail address to receive notifications from the system, do not use a Company e-mail address;
• do not submit your report from your work computer.