Whistleblowing

In line with international best practices and in full compliance with applicable regulations, Mundys S.p.A. has implemented, since 2003, and periodically updated a process for collecting and managing Reports. The current whistleblowing management system features the following:

• management of whistleblowing in each Group Company, through specific whistleblowing channels and accountability to the Whistleblowing Committee in the interests of timeliness and effective analysis, except for common safeguarding requirements of the Mundys Group and/or the holding company Mundys S.p.A.;
• provision of common mechanisms for detecting and managing any conflicts of interest in the process of managing Reports;
• the assignment, without prejudice to the collegiality of the Whistleblowing Committee, of a key role to a specific function (e.g. Internal Audit or Compliance) in managing process, from receipt of Reports to implementation of the preliminary investigation;
• provision of information flows with the other actors in the Internal Control and Risk Management System.

In order to ensure the effectiveness of the reporting process and provide total and non-discriminatory access to all those who wish to make a Report concerning Mundys S.p.A., the company provides an IT platform accessible to all (employees, third parties, etc.) via the “Whistleblowing – Mundys” section of the company website and the Mundys intranet, where a written or oral Report may be submitted.

Oral Reports may also be made through a direct meeting with the Whistleblowing Committee or one or more of its members¹, upon request by Whistleblower. Such request can be submitted via the platform or addressed to one of the Committee members.

Although submission of Anonymous Reports is a feasible alternative at Mundys, the Group recommends the submission of a non-anonymous Report, in order to speed up and facilitate investigations.

Guarantees and protections for the Whistleblower are set out in a dedicated section, to which referenced should be made (see paragraph “Confidentiality of the Reporting Subject’s identity” of Mundys Guidelines).

For all those who wish to make a disclosure concerning other companies in the Group, specific channels are available on their respective websites, with the exception of Azzurra Aeroporti S.p.A. and Spea Engineering S.p.A., for which it is possible to use the Mundys S.p.A. platform by appropriately selecting the company subject to the report.

Our Whistleblowing Committee

The members of Mundys Whistleblowing Committee, set up by the Chief Executive Officer, are as follows:

Mundys Whistleblowing Committee performs the following main tasks:

• it is responsible for the process of managing disclosures, assessing their adequacy and suggesting to the Board of Directors any improvements to the process, promoting the necessary information and training initiatives for the Group’s personnel;
• it supervises compliance with the Code of Ethics, examining reports of possible breaches and promoting the necessary checks and, where required, the consequent improvement actions, monitoring their effective implementation;
• it disseminates and verifies awareness of the Code of Ethics, promoting communication initiatives and activities aimed at increasing understanding of the Code;
• it proposes the issuance of guidelines and operating procedures or additions and amendments to existing ones, aimed at reducing the risk of breaches of the Code.

The Whistleblowing Committee is coordinated by the Internal Audit, Risk and Compliance Officer.

Mundys S.p.A.’s Whistleblowing Committee, following an ad hoc assessment, may reserve the right to handle Significant Reports concerning facts potentially capable of causing significant impacts (e.g., facts involving top management, cases of fraud or corruption, human rights violations, or other situations that could potentially constitute criminal offenses).