Whistleblowing Report

Process Management.

General Organizational Model pursuant to Legislative Decree 231/01, as amended

GRAFFER Srl has adopted a Compliance Management System—the General Organizational Model pursuant to Legislative Decree 231/01, as amended—to manage its processes and activities, which governs the administrative liability of legal entities. An integral and fundamental part of the General Organizational Model pursuant to Legislative Decree 231/01 and subsequent amendments is the Code of Ethics and Conduct, the current version of which can be downloaded from the company website www.graffer.it. This Code sets forth the principles and behavioral guidelines that must govern the relationships between GRAFFER Srl and the third parties referred to in these emails. The Code of Ethics and Conduct referred to in the Introduction and the company website list the Internal and External Reporting Channels through which violations and/or irregularities—including potential and/or attempted ones (whistleblowing)—regarding the management of relations between GRAFFER SRL and other third parties involved in the subject matter of this email may be reported

The Internal Reporting Channels are as follows:

a) Registered letter with return receipt addressed to GRAFFER Srl, Via L.TELLAROLI 5/N, LONATO DEL GARDA BS, for the attention of the 231 Supervisory Body

b) Email: segnalazioni231@graffer.it forwarded to the 231 Supervisory Body

Il Canale Segnalativo Esterno è  Sito Portale ANAC Autorità Nazionale Anti-Corruzione www.anticorruzione.it .

Reports will be handled in a manner that protects whistleblowers, in accordance with Legislative Decree 24/0023, as amended, on whistleblowing, and in accordance with the confidentiality provisions of Legislative Decree 196/03, as amended, on privacy.