Legal notices

We hereby inform you that, as established by Legislative Decree no. 24 of 10 March 2023 and the ANAC (National Anti-Corruption Authority) Guidelines pursuant to Resolution no. 311/2023, our company MAK SpA has prepared and approved an internal procedure for the transmission and management of reports of illicit conduct and violations (so-called whistleblowing ).

More specifically, we would like to inform you that an internal channel has been activated for reporting any unlawful conduct or violations of the law learned in the workplace.

The primary purpose of whistleblowing is to identify risks and/or situations potentially detrimental to the company in order to resolve or, if possible, prevent any problems that could arise from corporate wrongdoing or a regulatory violation. This allows critical issues to be addressed quickly and with the necessary confidentiality, while ensuring maximum transparency and fairness.

The internal channel cannot therefore be used, for example, to report disputes, claims, or requests related to a personal interest and which pertain exclusively to one's individual employment relationship, or inherent to one's employment relationship with hierarchically superior figures.

The aforementioned internal reporting channel and the whistleblowing procedure in general have been approved by the Board of Directors of MAK SpA and will be overseen by specifically trained and experienced personnel. Reports will be received and handled, according to the principles of autonomy, independence, and objectivity, by an external consultant specifically appointed by the company.

The reporting channel also ensures adequate security standards to protect the identity of the whistleblowers, the individuals involved, and any individuals mentioned in the report, as well as the content of the report and related documentation, in compliance with data processing and privacy regulations.

Reporting procedures are written and verbal, in accordance with the provisions of Legislative Decree 24/2023 and the clarifications provided by the ANAC. Specifically, an IT platform has been set up, which whistleblowers can access and use to submit reports in strictest confidentiality.

The recipient and manager of the reports, once a report has been received:

• within seven days of receiving the report, will issue the reporting party with an acknowledgement of receipt of the report;
• will subsequently follow up on the report received;
• may request from the reporting party, if necessary, any additions relating to the information included in the report made;
• will provide a response to the report within three months of the date of the acknowledgement of receipt or, in the absence of such acknowledgement, within three months of the expiry of the seven-day period from the submission of the correctly formalized and addressed report.

If a channel within the company is activated that does not comply with the provisions of Legislative Decree 24/2023, or if the whistleblower has filed an internal report and it has not been followed up, or if the whistleblower has reasonable grounds to believe that filing an internal report would not be effectively followed up, or that the report could lead to the risk of retaliation, or if the whistleblower has reasonable grounds to believe that the violation could constitute an imminent or manifest danger to the public interest, the whistleblower may contact the ANAC (National Anti-Corruption Authority) directly to report any unlawful conduct or violations (external channel), as further specified in the whistleblowing procedure adopted by the company.

All information regarding the reporting procedures will also be displayed and made easily visible and accessible to interested parties in a dedicated section of the Company's website.

Each employee/collaborator can make reports by accessing the following link:

makspa.segnalachi.it