The Calzedonia Group strongly encourages anyone concerned to report any unlawful conduct, violations of Model 231 and of Italian Legislative Decree no. 231/2001, of the Code of Ethics and of the Suppliers' Code of Conduct, as well as any conduct that may cause damage or harm, including of a reputational nature, to the Calzedonia Group.  

To this end, the Calzedonia Group has taken steps to regulate the whistleblowing process, in order to guarantee potential whistleblowers the confidentiality of their identity, the correct and prompt handling of reports made and protection from any acts of retaliation.

Anyone working in the company's work environment can make a report, whether classed as:

• employees;
• self-employed workers and collaborators working for the Group;
• freelance professionals and consultants working for the Group;
• volunteers and trainees, both paid and unpaid, who work for the Group;
• shareholders and persons with administrative, management, control, supervisory or representative duties, even if such duties are exercised on a de facto basis, for the Group
  even when the legal relationship has not yet commenced, if information about violations was acquired during the selection process or at other pre-contractual stages or during the trial period or after termination of the legal relationship if information about violations was acquired during the course of the relationship.

The Calzedonia Group has made available an external digital platform, managed by a specialised third party, in order to provide easy access to all those who wish to make a report and to guarantee the effectiveness and confidentiality of the process of handling it. The platform can be accessed at https://calzedonia-whistleblowing.keisdata.it

Reports can also be made verbally using special voice messaging systems provided by the same digital platform.

The platform is available in all languages of the countries where Calzedonia Group companies are present.

Alternatively, to make a report, a physical letter can be mailed to:

Organismo di Vigilanza [Supervisory Body] c/o Calzedonia Spa, Via Monte Baldo n. 20, Dossobuono di Villafranca (VR)

Reports may also be made anonymously; however, it is recommended that they be made by name in order to allow for more efficient investigation activities. The safeguards provided for and granted by the legislation will in any case apply.

The report, whether anonymous or otherwise, must be substantiated and based on precise and concordant elements, of which the whistleblower has become aware in the course of their work, so as to provide any useful element to allow an appropriate verification of the validity of the facts reported.

The whistleblowing channel manager acts as follows:

• the whistleblower is given acknowledgement of receipt of the report within seven days of receipt;
• dialogue is maintained via the platform with the whistleblower and additional information is requested, if necessary;
• a diligent follow-up is assured on all reports received by activating the persons in charge of handling such reports;
• acknowledgement is given of the report within three months of the date of the acknowledgement of receipt or, in the absence of such an acknowledgement, within three months of the expiry of the seven-day period from when the report is made.

Relevant reports are those concerning conduct, acts or omissions which harm the public interest or the integrity of the Calzedonia Group, of which the whistleblower has become aware in the context of work and which consist of:

• unlawful conduct relevant under Legislative Decree no. 231/2001 and violations of Model 231, such as, for example, corrupt conduct towards the Public Administration, physical or verbal harassment, violations of Health and Safety at work, and violations of Environmental regulations;
• offences falling within the scope of European Union acts in the following segments: public tenders; services, products and financial markets and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; privacy and data protection; and network and information system security; 
• acts or omissions that harm the financial interests of the European Union;
• acts or omissions relating to the domestic market, including violations of EU competition and state aid rules and corporate taxation;
• acts or conduct that frustrate the object or purpose of the provisions of the above-mentioned European Union acts.

Reports other than those described above, in particular those referring to objections, claims or demands linked to a personal interest of the whistleblower that relates exclusively to their individual employment relations, or is inherent to their employment relations with hierarchically superior figures.

In the event of unfounded reports, reports made in bad faith or with serious negligence, the Calzedonia Group reserves the right to act in defence of its own interests or those of the individuals harmed by the unfounded report.

In order to ensure proper processing, the report must be as detailed as possible in order to enable the competent persons to receive and handle reports to verify the facts. Specifically, the whistleblower should:

• report in a clear, complete and substantiated manner the events being reported, the manner in which he/she became aware of them and the date and place where they occurred;
• provide general details or other information enabling the persons involved to be identified;
• indicate any other subjects who may be able to report on the events reported;
• indicate/provide any documents that may confirm the validity of the report;
• provide any other information that may prove useful in investigating the events reported.