Business ethics

What is Whistleblowing?

The Whistleblowing protects people who report violations of national or European Union regulatory provisions that harm the public interest or the integrity of the public administration or private entity of which they have become aware in their work context.

Why is it important?

Because you can now report a violation, behavior, act, or omission that harms the integrity of the company or the public interest. FRASCOLD S.p.A. promotes the dissemination and use of whistleblowing as a fundamental measure to prevent and combat corruption and illegal conduct, as well as to protect whistleblowers.

What is FRASCOLD Whistleblowing policy?

FRASCOLD S.p.A.'s Whistleblowing Policy regulates the process of sending, receiving, analysing and processing - including archiving and deleting - reports from anyone coming from or transmitted, even in confidential or anonymous form, as well as protecting the Whistleblower and the persons involved.

How can I report violations?

You can do this through the following internal channels:

• through the IT platform accessible from the Company's website;
• in paper form, by letter sent with confidential/personal wording to the address: Via Barbara Melzi, 103/105, 20027 Rescaldina (MI), for the attention of the Whistleblowing Committee;
• direct meeting with the Whistleblowing Committee; The names are in the policy document;
• through a voice messaging and morphing system accessible from the Company's website.

Only in certain circumstances via external channels:

• made available to the National Anti-Corruption Authority (ANAC);
• public dissemination (press, social networks, etc.).

What protection for those who report violations?

The Company guarantees the absolute confidentiality of the identity of the Whistleblower, the Person Involved and the person mentioned in the report. Who, under the conditions set out in the Whistleblowing Policy, makes the report is protected by the prohibition of retaliation, even indirect, against him (including, dismissal, suspension, demotion in rank or failure to promote, demotion, negative references, intimidation or harassment, reputational damage, etc.).

The following are not considered violations and therefore do not apply:

• disputes, claims or requests related to a personal interest of the Whistleblower;
• complaints relating to activities of a commercial nature (e.g. complaints).

The Company will take the most appropriate disciplinary and/or legal measures against anyone who improperly uses the whistleblowing channels by making reports with intent or gross negligence that prove to be unfounded or opportunistic and/or for the sole purpose of slandering, defaming or causing unjust damage and/or prejudice to the Person Involved or to other subjects mentioned in the report.

The ethical code of Frascold is firmly grounded on the essential pillars of integrity, respect, and fairness, which serve as fundamental cornerstones to guide actions and behaviors adopted within the company. These principles, irreplaceable within the outlined ethical framework, form the basis upon which Frascold's corporate culture is built, directing relationships with employees, customers, suppliers, and other stakeholders. The promotion of an environment characterized by transparency, loyalty, and justice underscores the company's ongoing commitment to foster ethical and responsible conduct, reflecting its proactive role in society and the industry.

Frascold embraces the Organizational, Management, and Control Model in compliance with Legislative Decree 231/2001 as a fundamental pillar of its corporate philosophy. The adoption of these regulations is not only a legal requirement but also reflects its intrinsic commitment to transparency, integrity, and corporate responsibility. Frascold recognizes the need to create an ethical and proper environment, promoting a corporate culture that values honesty and compliance with laws. The implementation of the Model 231/2001 not only ensures legal compliance but also reflects the company's ongoing commitment to operate at the highest ethical and regulatory standards.

The Supervisory Body of Frascold has the task to oversee:

• the effective capability of the Model 231 to prevent the commission of crimes provided for by Legislative Decree 231/2001
• the observance of the requirements of Model 231 by its recipients
• the update of Model 231

Composition of the Supervisory Body (appointed by the Board of Directors on 19 July 2023):

• Ottorino Capparelli (president)
• Francesco di Leo (external member)
• Vittorio Carnevali (internal member)

The supervisory body can be contacted at the following e-mail address odv_frascold@arubapec.it