DANI S.p.A has long since adopted the regulations in accordance to Legislative Decree. 231/2001, which introduced in Italy the “Discipline of the administrative responsibility of legal persons, companies and associations also without legal personality”.

In order to achieve the principles of correctness and transparency, DANI S.p.A is in line with its model 231 and has implemented:
a CODE OF ETHICS (available at www.gruppodani.it). The Code of Ethics contains the fundamental principles that govern, the Rules of Conduct and Human rights for all activities at DANI S.p.A.
A special Supervisory Board (ODV) (ODV) that supervises and verifies the correct and full application of Model 231/2001.

All employees, agents, consultants, suppliers, independent contractors and representatives of DANI S.p.A are responsible for reading, understanding and complying with the principles and standards contained in this Code.

More precisely, in compliance with the Model, DANI S.p.A. has adopted a Whistleblowing Policy (complying with Italian Legislative Decree no. 24 of 10 March 2023).

MATTERS THAT CAN BE REPORTED

Any violation of Italian and/or European Union legislation, even if not yet committed, discovered in a work-related context and relating to one or more of the following matters:

Breaches falling within the scope of application of European Union or national regulations relating to the following sectors:

i) public procurement

ii) financial services, products and markets and prevention of money laundering and terrorist financing

iii) product safety and conformity

iv) transport safety

v) protection of the environment

vi) radioprotection and nuclear security

vii) animal feed safety, health and wellbeing

viii) public health

ix) consumer protection

x) safeguarding privacy and protection of personal data and security of IT networks and systems

Breaches that damage the financial interests of the Union referred to in article 325 TFEU and further specified in the relevant Union measures

Breaches relating to the internal market, referred to in article 26(2) TFEU, including infringements of Union law regulating
competition and State aid, as well as breaches regarding the internal market connected with acts infringing corporate tax regulations or mechanisms aimed at obtaining a fiscal benefit that negatively affects the purpose and the aim of the corporate tax regulations applying

OMM - Organisation and Management Model Leg. Decree 231

· breaches of the Code of Ethics; 
· breaches the Organisation and Management Model adopted; 
· illegal conduct as defined by Italian Legislative Decree no. 231 of 8 June 2001, as amended and supplemented.

MATTERS THAT CANNOT BE REPORTED

The following will not be processed:

· reports that do not concern breaches of the Code of Ethics, the Organisation and Management Model adopted or, in any event, relate to breaches that do not constitute illegal conduct as defined in Italian Legislative Decree no. 231 of 8 June 2001, as amended and supplemented;

· complaints, claims or requests linked to an interest of a personal nature of the Reporting person, which relate exclusively to his or her individual working relations, or relate to his or her working relations with superiors;

· reports of breaches which are already mandatorily regulated under Italian or European Union legislation regulating financial services, products and markets and prevention of money laundering and terrorist financing, transport safety;

· reports of breaches relating to national security, as well as public procurement relating to aspects of defence or national security, unless those aspects are covered by secondary law relating to the European Union;

· information clearly lacking any foundation, information that is entirely in the public domain, as well as information obtained solely through indiscretion or clamour that is not reliable (referred to as rumours).

REPORTING PROCEDURES

1) INTERNAL CHANNELS

The Company has made internal channels available that guarantee the confidentiality of the reporting person, of the person reported and/or in any way involved in the report, and the contents of the report. The management of the internal channels is assigned to a specifically appointed competent, autonomous and skilled subject (“Manager”).

a. IT PLATFORM

The reporting person may submit a report using the platform accessible via the link on the website https://whistledani.gruppodani...

The platform allows reports to be submitted either orally or in written form.

b. WRITTEN REPORT

The Reporting person can make a written report by registered mail with advice of receipt.

For this purpose, the report must be inserted in two sealed envelopes, the first containing data identifying the Reporting person and the second, the matter disclosed. Both envelopes must then be inserted in a third envelope addressed to:

DANI S.p.A.

Via Della Concia, 186

36071 – Arzignano (VI)

RESERVED for the Manager of the whistleblowing reporting channel.

This internal paper-based channel cannot be used to make an anonymous report.

c. DIRECT MEETING

The Reporting person may request a direct meeting, using one of the three methods described above. The Manager will reply to the Reporting person informing him/her where the direct meeting requested is to take place and the procedures to be followed.

ANONYMOUS REPORT

Reports from which it is not possible to deduce the identity of the Reporting person are considered as anonymous.

Although the company accepts anonymous reports, it encourages whistleblowers to provide their names, so that investigations can be carried out swiftly and efficiently.

The Manager follows up anonymous reports however, when the matters reported have been described in adequate detail, that is, are capable of revealing facts and situations, described in specific contexts.

Anonymous reports are managed through the internal IT platform.

2) EXTERNAL CHANNEL

The external reporting channel is activated by "ANAC": the National Anti-Corruption Authority (ANAC) https://www.anticorruzione.it/.

The Reporting person may submit a report externally if, when his or her report is submitted:

a) the internal reporting Channel is not operative or does not comply with the Decree;

b) he or she has already submitted an internal report in compliance with the Decree, which has not been followed up;

c) he or she has well-founded grounds to believe that submitting an internal report would not be effectively followed up, or that the report submitted could expose the Reporting person to a risk of retaliation;

d) he or she has well-founded grounds to believe that the breach may constitute an imminent or obvious danger to the public interest.