The Cedacri Group promotes the adoption of tools aimed at preventing, detecting and communicating unlawful conduct and/or conduct in violation of the Group's ethical principles. To this end, legal representatives, directors, managers and employees of Cedacri companies and other third parties who interact with the Group are encouraged to report any material violation of which they become aware.

Reporting Unlawful Conduct
The Cedacri Group has set up specific channels, processes and procedures to ensure confidentiality and protect those who report unlawful conduct. Reports may relate to a variety of violations, including, but not limited to:
• Violations of the Group's Code of Ethics;
• Unlawful conduct pursuant to Legislative Decree 231/2001;
• Violations of antitrust laws;
• Corruption;
• Conflicts of interest;
• Corporate fraud;
• Harassment;
• Administrative, accounting, civil or criminal offences.

Reporting Channels
Reports can be made through the following channels:
1. via Web: https://ewhistle.cedacri.it/
2. by phone: 05211922024 / 01311923024
o If you want to submit an anonymous report, prefix #31# (e.g.: #31#05211922024)
The channels indicated must not be used for complaints of a personal nature of the whistleblower or claims/requests that fall within the discipline of the employment relationship or relations with the hierarchical superior or colleagues, for which reference must be made to the Human Resources and Group Organization function.

Confidentiality and Processing of Information
Cedacri guarantees the confidentiality of the identity of the Whistleblower and any other information from which such identity can be inferred, directly or indirectly, without the express consent of the reporting person. The confidentiality of the information contained in the reports is also protected at every stage of the reporting process, to the extent that anonymity and confidentiality are enforceable according to the law; the measures to protect the confidentiality of the Whistleblower are aimed, among other things, at ensuring that the same is not subject to any form of retaliation.

External Reporting Channels
The Cedacri Group encourages employees to make use of internal channels as a matter of priority. It is always possible for the Whistleblower to make the Report also through the use of the following external Reporting channels:
• channel at the National Anti-Corruption Authority: from the ANAC - www.anticorruzione.it website which guarantees, also through the use of encryption tools, the confidentiality of the identity of the reporting person, the person involved and the person mentioned in the report, as well as the content of the report and the related documentation;
• Public disclosure, i.e. making information on violations public through the press or electronic means or in any case through means of dissemination capable of reaching a large number of people;
• report to the judicial or accounting authority.

As a matter of priority, the use of the internal channel is favoured and, only under one of the following conditions, can an external report be made:
• there is no mandatory activation of the internal reporting channel within the working context of the whistleblower, i.e. this, even if mandatory, is not active or, even if activated, does not comply with the provisions of Article 4 of Legislative Decree 24/2023;
• the reporting person has already made an internal report pursuant to Article 4 of Legislative Decree 24/2023 and the same has not been followed up;
• the reporting person has reasonable grounds to believe that, if the reporting person were to make an internal report, it would not be effectively followed up or that the report could lead to a risk of retaliation;
• The reporting person has reasonable grounds to believe that the breach may constitute an imminent or obvious danger to the public interest.

In addition, the Reporting Person may also contact ANAC to notify any retaliatory acts resulting from a report.

Reports external to ANAC can be made according to the procedures provided on the institution's institutional website.

Gruppo Cedacri informativa trattamento dati whistleblowing