GT Line Code of Ethics - Whistleblowing

This awareness and sense of responsibility with regard to the above-mentioned issues has led the company to identify the values that guide its behaviour and to consolidate them in its Code of Ethics. In this way, GT Line wanted to define standards of conduct aimed at ensuring compliance with the rules and regulations governing company life and relations with third parties, as well as protecting the health and safety of all direct and indirect employees, the environment and respect for people who work there and anyone who comes into contact with GT Line’s plants, products and property.

The values and principles of conduct enshrined in the Code of Ethics are an inspiration for promoting and improving the cultural development of the entire organisation and of each individual working for GT Line, influencing their levels of motivation, creating awareness and requiring commitment at all levels of the organisation to encourage the development of conscious, transparent, responsible and safe behaviour.

For this reason, in order to establish and maintain professional relations with third parties, GT Line considers it essential that all those who act in the name, on behalf or in the interest of GT Line Srl know and accept the values and principles of conduct set out in the Code of Ethics.

[Code of Ethics Attachment]

In accordance with the principles laid down in the Code of Ethics and with a view to promoting a culture of legality, GT Line has also adopted an organisational, management and control model that complies with the requirements of Art. 6 of Legislative Decree No. 231 of 8 June 2001 on “Administrative Liability of Legal Persons and Entities”.

The principles of conduct set out in the Code of Ethics are put into practice in the above model through the implementation of “prevention protocols” in the various areas of activity where there is a risk of committing one of the offences listed in Legislative Decree No. 231/2001. The prevention protocols have been designed and implemented using an approach that, on the one hand, develops people’s management skills and, on the other, improves the overall internal control system through a balanced and integrated view of the cause-and-effect relationships that exist within the company’s dynamics.

The definition, adoption and implementation of a model such as the one described above has been, and continues to be, for GT Line, beyond the provisions of Legislative Decree No. 231/2001, an effective means of raising the awareness of all those who work in its name or on its behalf, so that they adopt correct and fair conduct in the performance of their activities, thus avoiding the risk of committing the offences provided for in the aforementioned Decree.

The organisational, management and control model adopted by GT Line has been drawn up and is regularly updated on the basis of a detailed risk assessment aimed at identifying the areas of the company exposed to the risk of offences being committed and assessing the effectiveness of the preventive measures.

GT Line has also set up a collegiate Supervisory Board whose task is to carry out systematic checks on the effective and practical implementation of the provisions contained in the Model, and to assess its adequacy in the light of legislative changes, jurisprudential developments and organisational and procedural changes that may occur in the management of the company over time.

The Supervisory Board can be contacted at the addresses below to clarify the content of the organisation, management and control model and to provide useful information flows to support the planning of its own supervisory initiatives:

email: odv@gtline.it

ordinary mail: GT Line Srl single-member company – for the attention of the Supervisory Board, via del Lavoro 9 Località Crespellano, 40053 Valsamoggia (BO) – ITALY

In accordance with the regulations governing the subject of whistleblowing, GT Line has established specific internal whistleblowing channels and, after consultation with trade union representatives, has adopted a specific Whistleblowing Management Policy – attached below – which details the methods of submission and management under the principles of confidentiality and protection of the persons making such communications. To follow are some key excerpts from the policy:

How to make a report

To securely submit a report, simply log in to the whistleblowing platform at: HTTPS://GTLINE.WHISTLELINK.COM and leave a written or oral message. It is important to note the access codes provided by the platform in order to be able to log in at a later stage to check that the report has been taken into account, any request for further investigation and notification of the completion of the investigation.

It is also possible to request a one-to-one meeting with the Supervisory Board – at one of the above-mentioned addresses – in order to submit your report directly.

Only if certain requirements are met, it is also possible to submit a report through channels outside the organisation/company or to make public disclosure.

How personal data will be processed

Personal data from whistleblowing will be processed in the manner indicated in the information provided pursuant to articles 13 and 14 of the General Data Protection Regulation (GDPR). The policy can be found on the whistleblowing platform, in an area prior to the possible submission of a report.

The whistleblowing platform is external to the company domain, resides at a third-party provider, guaranteeing independence, and is equipped with the most advanced security techniques to ensure data protection.

What can and cannot be reported

It is possible to report violations of laws and regulations as well as irregular conduct that harms the public interest and the integrity of GT Line Srl’s administration. This includes, in particular, conduct contrary to the Code of Ethics and the GT Line organisation, management and control model.

It is not possible to report disputes, claims or requests linked to a personal interest of the whistleblower that relate exclusively to their individual work or public employment relationships, or inherent in their work or public employment relationships with hierarchically superior figures.

Likewise, this channel is not intended to accommodate requests, complaints or disputes of a technical or commercial nature. We therefore invite customers to refer to the appropriate communication channels provided by GT Line in other sections of this website.

Any reports with the aforementioned content cannot, therefore, be taken into consideration and will be archived.

The submission of inadmissible reports under the above provisions does not allow the protection afforded by the legislation in force to be extended to the whistleblower.

How the confidentiality of the whistleblower is protected

The report will be handled by the Supervisory Board, a collegial body appointed pursuant to Art. 6 of Legislative Decree No. 231/2001 and also made up of professionals from outside the company with proven autonomy and independence.

The whistleblower can decide if to provide their identification details in order to facilitate interaction. Under no circumstances may the identity details of the whistleblower – where provided – be disclosed to persons other than those authorised to handle the report. Disclosure of identifying information may be necessary in order to proceed with the launch of possible disciplinary action against third parties in cases where the information emerging from the investigation is not sufficient for autonomous action. In such cases, the whistleblower will always be asked in advance for permission to disclose their identity.

Whistleblowing can also be done anonymously. In this case, it is essential to note the access codes issued by the platform at the end of the report in order to ensure proper interaction with the Supervisory Board.

What protections are afforded to the whistleblower and those associated with the whistleblower?

The relevant legislation provides for specific and extensive forms of protection for whistleblowers and those who have facilitated their reporting, as well as for colleagues, relatives and dependants who may be affected in any way by discriminatory or retaliatory acts.

Protection is provided directly by the Labour Inspectorate through the Anti-Corruption Agency (ANAC).

Finally, ANAC provides a list of local organisations that can be contacted for assistance and psychological support in the event of discriminatory or retaliatory acts.

Good faith

The whistleblowing platform is intended for use by those who, in good faith and in accordance with ethical principles of integrity, report conduct that potentially does not comply with laws and regulations or GT Line’s internal principles and procedures of which they have become aware.

The whistleblower is only protected by the legal system if, at the time of the report, they had reasonable grounds to believe that the information on the reported violations was true and fell within the above-mentioned objective scope.

Failure to comply with the above will result in GT Line taking action against those who have made reports in bad faith, with malicious or grossly negligent defamatory intent, or who do not act in a proper spirit of cooperation with the company.

[Attached Whistleblowing Management Policy]