Whistleblowing is a tool aimed at preventing unlawful conduct committed within a company. Whistleblowing occurs when an employee - or another person who, for whatever reason, works in the context of the Company, such as a collaborator, a shareholder, a supplier, etc. [1]  - (the "Whistleblower") reports unlawful conduct of which he/she has become aware during the exercise of his/her working activity in the corporate environment.

In compliance with the provisions of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law and on the protection of persons who report breaches of national laws", Scandstick AB (also the “Company”) has taken steps to adopt an appropriate system for making and managing reports of breaches occurring within the work context.

For the above-mentioned reports, the Company makes available a specific reporting channel, which is suitable for guaranteeing, also by means of appropriate cryptographic tools, the confidentiality of the identity of the Whistleblower and of any persons reported, as well as the content of the report.

In particular, information on potential violations can be communicated to the Whistleblowing Committee - specifically established and composed of CHIARA LIGUORI and SILVIA CALUSI (Legal Department Europe) - which will handle the reports by virtue of its distinguishing characteristics of impartiality and independence - through the Platform, made available by the Company on its website.

The Platform allows reporting in two different ways:

• in writing, by filling in the dedicated online form;
• in oral mode, by means of the voice messaging function through which the Whistleblower can record a voice message that will be, via the Platform, saved and stored.

For further details in relation to the indications for making reports, please refer to the enclosed "Whistleblowing Procedure".

In order to promote the so-called "Whistleblowing culture", Scandstick AB admits the receipt and handling of reports also in anonymous form.

Reports may concern:

• unlawful acts under EU acts in the areas of: public procurement; services, products and financial markets and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; privacy and personal data protection; and network and information system security;
• acts or omissions affecting the financial interests of the Union;
• acts or omissions concerning the internal market (e.g. competition and state aid violations);
• acts or conduct that frustrate the object or purpose of the provisions contained in Union acts.

In compliance with the above-mentioned regulations, Scandstick AB adopts all the necessary measures aimed at protecting the confidentiality of the identity of the Whistleblower. Furthermore, the Company imposes the absolute prohibition of retaliatory or discriminatory acts, direct or indirect, against the Whistleblower for reasons directly or indirectly related to the Whistleblowing report, with the provision of sanctions against those who violate such protection measures.

For any further information on this, please refer to the dedicated 'Whistleblowing Procedure', which can be reached by clicking here.

If you have any doubts or queries concerning the application of the 'Whistleblowing Procedure', please contact the Legal Dept. Europe.

[1] Scandstick AB S.r.l. guarantees the reception, analysis and processing of the reports forwarded by those who are entitled to make a Whistleblowing report, i.e. employees of the Company, collaborators, freelancers or consultants collaborating with the Company, trainees and volunteers, directors and shareholders and members of corporate bodies (Board of Directors, Board of Statutory Auditors, etc.). For any further details, see the "Whistleblowing Procedure" dedicated to this.