ADR Group Whistleblowing

The ADR Group Companies have implemented a Whistleblowing Management process, updated in accordance with Legislative Decree No. 24 of 10 March 2023 on the Implementation 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 laying down provisions regarding the protection of persons who report breaches of national laws.
The main elements of the reporting management system are:

• a multidisciplinary Whistleblowing Team in charge to receive and manage whistleblowings; The Whistleblowing Team members are the Vice Presidents (i) Internal Audit (acting as Coordinator), (ii) Human Capital & Organization, Health & Safety, (iii) Legal & Corporate Affairs, (iv) Finance & Administration and (v) Risk Governance & Compliance;
• dedicated communication channels for receiving and managing whistleblowings.

In order to ensure the effectiveness of the reporting process and to provide broad and indiscriminate access to all those who wish to make a whistleblowing disclosure, ADR makes available a range of alternative reporting channels, specifically

• information technology platform, accessible by all Whistleblowers (Employees, Third Parties, etc.) on ADR's website, which allows reports to be made in written and oral form;
• e-mail, at the e-mail address: segnalazioni.adr@adr.it;
• postal mail, to the address: ADR S.p.A., Team Segnalazioni ADR, Via Pier Paolo Racchetti 1, 00054 Fiumicino (RM).

In addition to the above channels, oral reports may also be made through a direct contact with the Whistleblowing Team or one or more of its members, at the request of the whistleblower.
Whenever possible, the use of the first channel (information technology platform) is preferred. Similarly, although anonymous whistleblowing is a feasible alternative in ADR, the ADR Group Companies suggest that whistleblowers prefer to use nominative whistleblowing, for the benefit of the speed and effectiveness of investigations.
The platform makes it possible to select the ADR Group companies to which the report is deemed to refer, if known, so that it can be promptly directed to the proper management channels.
For details on the guarantees and protections for the Whistleblower and reported person, please refer to the Whistleblowing Policy, available on this webpage.

What can you report?
The Whistleblowing Management System, in accordance with Legislative Decree 24/2023, is aimed at Top Management, members of the Corporate Bodies, employees (e.g. direct, indirect, trainees, interns) and third parties in general (e.g. customers, suppliers and consultants) who are entitled to make a report if they have information about violations - i.e. conduct, acts or omissions that harm the public interest or the integrity of the company or the Group - (or alleged violations) of

• Laws and Regulations;
• Code of Ethics;
• Model 231;
• Anti-Corruption Policy;
• Conflict of Interest Management Procedure;
• Management System for the Prevention of Corruption;
• Internal corporate regulatory framework (policies, procedures, etc.);

as well as news of events likely to damage the assets or image of ADR Group Companies, according to the categories and cases provided for by Legislative Decree 24/2023.
In accordance with Legislative Decree no. 24/2023 and the Whistleblowing Policy, the whistleblower will be notified, through the channel used, of receipt of the report within 7 days from receipt and will be provided with feedback on the follow-up to the report within 3 months from receipt.
Complaints, claims or requests related to an interest of a personal nature of the person making the report, which relate exclusively to his individual work relations, or inherent to his work relations with hierarchically superior figures, do not fall within the scope of Legislative Decree 24/2023 and therefore of this Policy.