Whistleblowing

With Legislative Decree no. 24 of 10 March 2023, the Italian legal system has transposed Directive (EU) 2019/1937 on the protection of persons who report breaches ofEuropean Union Law (Whistleblowing Directive).

In compliance with Legislative Decree no. 24/2023, AB has set up an internal channel for the collection and management of whistleblowing reports capable of guaranteeing the confidentiality of the identity of the Whistleblowers involved in the report and the related documentation.

AB has adopted a policy that describes the operational instructions for using the channel, the management of reports, as well as the protection measures available to the subjects protected by the legislation.

Reports may come from different subjects, such as, but not limited to, employees, self-employed individuals, collaborators, freelancers, consultants, volunteers and trainees (including unpaid individuals), suppliers, shareholders or persons with administrative, management, control, supervision or representation functions, including de facto.

The reports, which must be as detailed as possible and must concern the breaches included in the scope of application of Art. 2 of Legislative Decree 24/2023. The legislation defines "breaches" all behaviors, acts or omissions that may damage the public interest or the integrity of the company concerned by the report, of which the Whistleblower has become aware within the AB business context. Reports outside the objective scope of application of the legislation will not be taken into consideration.

The management of the internal reporting channel and the assessment of the admissibility of the report are delegated to a Whistleblowing Committee within the AB Group. This Committee, in compliance with the deadlines indicated by the legislation, verifies the reported facts, guaranteeing confidentiality and objectivity, including any hearing of the Whistleblower and other parties involved. For this, the Committee can be supported by external consultants or by the competent company structures.

As a Residual Whistleblowers – and only in the specific circumstances outlined in the policy – can use an external reporting channel managed by ANAC (National Anti-Corruption Authority) available at https://www.anticorruzione.it/-/whistleblowing.

On a further residual basis and only subject to the specific circumstances defined in the policy, Whistleblowers can resort to public disclosure.