WHISTLEBLOWING

Dear users,

In implementation of Legislative Decree no. 24 of 10 March 2023, which transposed EU Directive 2019/1937, concerning "the protection of persons reporting violations of Union law" , our Company has implemented the so-called Whistleblowing system , through which anyone who deems it appropriate can choose to report, anonymously, confidentially and protectedly or directly, any situations relevant to the law or company regulations.

To submit reports, interested parties must use the link https://oti.openblow.it/# to access the company's dedicated management system, structured in accordance with the confidentiality and privacy guarantees imposed by current national and European laws regarding the protection of personal data.

The specific privacy policy is available on our website, at the following link: https://www.otiterapieinnovative.com/wp-content/uploads/2024/06/privacywhistleblowing.pdf

To make it as easy as possible for our users, we provide below a brief illustrative guide of the procedure to follow for submitting reports, in the form freely chosen by the reporter.

i) Our Company guarantees full protection for all individuals involved in reports, whether anonymous or direct, by implementing all data protection measures relating to their identity and the reported facts. The identity of the whistleblower may be disclosed only with their express consent, except where such disclosure is required by applicable law.

ii) Reports will be handled by the Supervisory Body appointed by our Company, whose total impartiality and independence is guaranteed.

iii) The report must concern exclusively non-compliance and/or failure to comply with current legislation or the Company's internal procedures and regulations, including the provisions contained in the 231 Organizational Model and the Code of Ethics, which can be consulted on the company website www.otiterapieinnovative.com.

iv) Reports that are not relevant for legal purposes will not be taken into consideration unless, from an investigation of the same, the occurrence of legally relevant facts can be identified.

v) Furthermore, only reports based on adequately described, detailed and consistent facts will be analysed.

vi) Any malicious or negligent reports that, following an investigation, prove to be unfounded may be subject to further investigation, including for the purposes of applying any disciplinary sanctions.

vii) In addition to the information provided, we invite you to read the procedure available on openblow https://www.openblow.it/funzionalita/

Procedure for submitting reports:

  1. The user must access the link: https://oti.openblow.it/#
  2. By clicking on “send a report”
  3. At this point, it will be possible to proceed with the reporting
    (a) anonymously using the appropriate option;
    (b) in a non-anonymous form, but in any case with the confidentiality guarantees required by law (do not use the company email address, as required by the Privacy Guarantor).
  4. Once the reporting method has been chosen, the reporter will proceed by filling in the appropriate form form.

For any further questions or clarifications, you can contact the Supervisory Body directly at ( odv@otiterapieinnovative.com ). Whistleblowing reports cannot be forwarded to this body, and will not be taken into consideration. For this purpose, only the institutional channels made available by the Company must be used.

Thanking you for your attention and remaining available to offer our users the best quality services, we send our cordial greetings.