Culture of legality

Patrigest S.p.A. has implemented and continuously updates its process of compliance with Legislative Decree no. 231 of 2001, aimed at preventing the organisation’s administrative and criminal liability. This process also serves to promote the principles that have always been at the basis of the Company’s and of the Gabetti Group’s operations, including protection of the culture of legality, training and transparency.

To this end, the Company has established its own prevention and self-monitoring system, consisting of the Organisational Model published and disseminated within the company, the procedures and protocols referred to therein, and the Code of Ethics: Click here to view the Gabetti Group’s Code of Ethics.

The Company has also established an autonomous and independent Supervisory Body that operates as a collective entity. In this regard and in accordance with the new whistleblowing framework, note that any reports concerning alleged conduct prohibited by law may be submitted to the Supervisory Body, including anonymously.

The reporting procedures supported by the Company are outlined below. Whistleblowing.

a) The Institute

Its purpose is to prevent the commission of offences and/or non-compliance, abuses or irregularities within the organisation, also with a view to involving stakeholders and the general public in efforts to combat illegality and inappropriate behaviour, through active and responsible participation. In other words, anyone taking the initiative (for example, an Employee, a Collaborator or a Supplier) may report unlawful conduct (or the risk of unlawful acts occurring) of which they have become aware as a result of their employment or contractual relationship.

b) What to report

The subject party may report alleged breaches committed (for example) by internal staff, directors, collaborators and business partners, relating to: – breaches of the Code of Ethics; – violation of the Organisational and Management Model pursuant to Legislative Decree 231/2001; – breaches of laws and regulations; – other violations.

c) How to file a report

You may submit the aforementioned report to the Company’s Supervisory Body (also referred to as SB) in one of the following ways:

– by email, specifying «Report pursuant to Legislative Decree no. 231/2001»; at the following email address of the Company’s SB: odvpatrigest@patrigest.it

– by ordinary registered post to the Company’s registered office, for the attention of the Company’s Supervisory Body.

It is not necessary for the Whistleblower to be certain that the events reported actually took place or to identify the perpetrator. However, the report must be made in good faith. Reports based on mere suspicion or rumours, or those that are purely defamatory, shall not be taken into consideration. Consequently, in order for it to be processed, the report must be detailed and accompanied by as much information as possible to help reconstruct the facts and enable the competent authority to verify them.