WHISTLEBLOWING NOTICE

Pursuant to the adoption of the Legislative Decree of 10 March 2023, n. 24, Riva Acciaio S.p.A. has set up the following channels to receive and manage whistleblowing.

Who can whistleblow?

• Associates and persons with administrative, management, control, supervision or representation functions, including when said functions are exercised informally, at Riva Acciaio S.p.A.;
• employed persons, interns, self-employed workers and consultants who work for Riva Acciaio S.p.A.;
• individuals who have had any of the aforementioned roles in the past in the event that the information regarding violations was acquired during the time when they had a relationship with Riva Acciaio S.p.A., and individuals whose relationship with Riva Acciaio S.p.A. has not yet begun - for example, job candidates or employees undergoing their probation period.

Whistleblowing scope

The list is very well-structured and comprehensive. For the sake of completeness, please refer to Legislative Decree 24/2023 ⁽¹⁾

Whistleblowing channels

freephone number: 800 – 134 – 307 (this call will be recorded)

email address: ra_whistleblowing@complegal.it

The whistle-blower also has the right to request a direct meeting with a professional outside the company, who manages the channel where the whistleblowing is raised, for a confidential discussion; the whistle-blower may use one of the two aforementioned channels to request said meeting and must include an address at which they wish to be contacted.

⁽¹⁾ As a general rule, any whistleblowing may cover matters regarding violations of the legal provisions of the European Union that affect public interests or the integrity of the company where the whistle-blower became aware of a professional context consisting in: relevant unlawful conduct pursuant to Decree 231 or violations of Model 231; offences that fall within the scope of European Union or national acts, or national acts that entail the implementation of European Union acts on the subject of public contracts; services, products and financial markets, the prevention of money laundering, and the financing of terrorism; product safety and compliance; transport safety; protection of the environment; radiation protection and nuclear safety; food and animal feed safety and the health and well-being of animals; public health; consumer protection; the protection of privacy, the protection of personal data, and the security of networks and information systems; acts or omissions that affect the financial interests of the European Union, pursuant to art. 325 of the Treaty on the Functioning of the European Union; acts or omissions regarding the internal market, pursuant to art. 26, par. 2, T.F.E.U. (including violations of competition rules and State aid, and violations regarding corporation tax); acts or types of conduct that, while not comprising an offence, jeopardise the content or purposes of the provisions referred to in the European Union Acts for the aforementioned sectors.

Any whistleblowing may also cover relevant unlawful types of conduct, pursuant to the Legislative Decree 231/2001 or violations of Model 231 adopted by the Company.