SUBJECT OF THE REPORT

There is no exhaustive list of crimes or irregularities that can constitute the subject of whistleblowing. Reports concerning behaviors, risks, crimes or irregularities, committed or attempted, to the detriment of the company and/or public interest, of which the employee/collaborator has become aware within the scope of or by reason of the employment relationship are considered relevant. .

In particular, the report may concern actions or omissions:

criminally relevant; implemented in violation of the Codes of Conduct (e.g. Code of Ethics, model 231/01) or other sanctionable company provisions or regulations; likely to cause financial or reputational damage to the Dental Clinic or to the employees or other subjects who carry out their activities at the company; likely to cause damage to the health or safety of employees and/or third parties.

Whistleblowing is not about reporting:

linked to a personal interest of the reporter (e.g. work disputes, interpersonal conflicts between colleagues, discrimination, claims that fall within the discipline of the employment relationship).

CONTENTS OF THE REPORT

The reporting party must provide all the useful elements to carry out the necessary checks and investigations to confirm the validity of the facts reported.

The report must therefore contain:

personal details of the reporting person, a clear and complete description of the facts, the circumstances of time and place in which the facts were committed (if known), the details of the person/s who committed the reported facts (if known), any documents that may confirm the facts

Anonymous reports will be taken into consideration for verification only if they relate to particularly serious facts.

METHOD AND RECIPIENTS OF THE REPORT

1) INTERNAL SIGNALING CHANNEL

The internal reporting channels, made available by Clinica, are adequate and suitable to ensure the confidentiality of the identity of the reporter.

Reports can be made in the form:

written: paper mail; oral: through a direct meeting with the report manager.

WRITTEN FORM

By paper mail (registered letters). The report must be inserted in two closed envelopes: the first with the reporting person's identification data together with a photocopy of the identification document; the second with the report, in order to separate the identifying data from the report. Both must then be placed in a third closed envelope bearing the words "reserved for the RPC" on the outside.

The reporting form can be found on the website or on the web noticeboard of the Centro Paghe Studio Web platform, where this procedure can also be found.

ORAL FORM

At the request of the whistleblower, a direct meeting is set up with the Corruption Prevention Manager, agreeing an appointment at the email address: rpc@clinicadentale.net. The meeting must be held within a reasonable time. At the end of the meeting, a report is drawn up which must also be signed by the reporting person. A copy of the report will be given to the person making the report.

2) REPORTING MANAGEMENT

a) Subject to whom the report is reported

The art. 4, paragraph 2, of the Decree provides that the management of the internal reporting channel can be entrusted to a natural person within the organisation. Clinica Dentale has therefore appointed an internal contact person, identified in the person of Dr. Fochesato Alessia.

This entity is dedicated and has autonomy in terms of verification and investigation (intended as impartiality and independence).

The subject appears to be specifically and adequately trained:

on privacy and is authorized to process personal data;

on the discipline of whistleblowing.

In light of its requirements, the identified subject is suitable to guarantee an adequate level of protection of confidentiality, the identity of the whistleblower and the content of the reports.

b) Receipt of the report

The manager of the report is required to provide the reporting party with the acknowledgment of receipt within seven days of submitting the report itself.

This notice must be forwarded to the address indicated by the whistleblower in the report. In the absence of this indication, it is possible to consider the report as unmanageable pursuant to the whistleblowing regulations and possibly treat it as an ordinary report.

In the case of anonymous reports, if they are timely and supported by suitable documentation, they will be equated with ordinary reports and therefore treated in accordance with internal regulations. In any case, anonymous reports must be recorded and stored.

c) Admissibility of the report

As a preliminary matter, an assessment must be carried out regarding the existence of the essential requirements of the report in order to evaluate its admissibility.

It is necessary to check:

if it falls within the subjective and objective perimeter of the law (who reported, what reported...) the presence of suitable elements to justify any investigations; that the report is precise and detailed, not generic and not defamatory; that the attached documentation is appropriate and coherent.

In the event that the report is inadmissible, it is archived while still guaranteeing the traceability of the supporting reasons.

d) Investigation and verification of the report

After having assessed the report as admissible, we proceed with the investigative activity (investigation) necessary to follow up on the report, through hearings and acquisition of documents.

The objective is to proceed with specific checks, analyzes and assessments regarding the reported facts, also in order to provide any recommendations regarding the adoption of necessary corrective actions.

Once the verification activity has been completed, the report manager can:

archive the report as unfounded, justifying the reasons; declare the report founded and contact the competent internal offices/functions for the related follow-up (the manager is not responsible for any assessment regarding individual responsibilities and subsequent measures).

All phases of the assessment must be traced, archived and kept for a maximum of 5 years. Pursuant to the provisions of the decree, the confidentiality of the identity of the reporter, the person reported and all the people involved and/or mentioned must be protected at all times.

e) Response to the reporter

The manager of the report must provide feedback to the reporter within three months from the date of acknowledgment of receipt.

At the end of the three months the following must therefore be communicated:

the filing, justifying the reasons; the verification of the validity of the report and its transmission to the competent internal functions; the activity carried out up to that moment and/or the activity you intend to carry out.

f) Reporting

The person responsible for managing reports prepares the report containing the reports received in the reference period on a six-monthly/annual basis. The report must include the status of each report and any actions taken.