Whistleblowing Policy (Legislative Decree 24/2023)

Legislative Decree no. 24 of March 10, 2023, implementing Directive (EU) 2019/1937 concerning the protection of persons reporting breaches of Union law and containing provisions regarding the protection of persons reporting breaches of national regulatory provisions, entered into force on March 15, 2023, and became operative on December 17, 2023, for companies that have adopted an Organization, Management, and Control Model pursuant to Legislative Decree of June 8, 2001, no. 231, or that have more than 50 employees.

What can be reported

Pursuant to the aforementioned legislation, relevant behaviors that can be reported include acts or omissions that harm the integrity of the Company and consist of:

• administrative, accounting, civil, or criminal offenses;
• unlawful conduct relevant under Legislative Decree no. 231 of 08.06.2001, or violations of the Organization and Management Model adopted by the Company;
• unlawful acts falling within the scope of application of European Union or national acts relating to the following sectors: public procurement; financial services, products and 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; protection of privacy and personal data and security of network and information systems;
• acts or omissions affecting the financial interests of the Union;
• acts or omissions concerning the internal market;
• acts or behaviors that undermine the object or purpose of the provisions of the Union acts.

Who can report

The following categories of individuals can make a report:

• Employees or collaborators;
• Suppliers, sub-suppliers and their employees and collaborators;
• Freelancers, consultants, self-employed workers;
• Volunteers and interns, paid or unpaid;
• Shareholders or persons with administrative, management, supervisory, control, or representation functions;
• Former employees, former collaborators;
• Persons who no longer hold one of the positions indicated above if the information on the violations was acquired during the relationship itself;
• Individuals undergoing selection, probation, or whose legal relationship with the entity has not yet begun.

Who is the Report Manager

The management of reports is entrusted to the Whistleblowing Report Manager, which coincides with the HR department.

The Report Manager, as the entity responsible for processing personal data, in accordance with the relevant legislation, requires that the data contained in the Reports be pertinent to the purposes set out in Legislative Decree 24/2023.

In particular, when describing the behavior giving rise to the Report, no information not strictly pertaining to its subject matter should be provided.

In case of Reports submitted in evident bad faith, the appointed managers reserve the right to archive them by deleting the names and elements that could allow the identification of the reported individuals.

How to report

In compliance with the aforementioned decree and relevant legislation, Boglioli Spa has established an internal reporting channel that guarantees, also through the use of encryption tools, the confidentiality of the identity of the reporting person, the person involved, and any person mentioned in the report, as well as the content of the report and related documentation.

Channels for submitting reports

Reports can be made by requesting a direct meeting with the Report Manager, in order to personally submit the Report. In this case, it is highlighted that:

1. the request must be explicit to the HR department staff member, who will provide a specific request receipt and the relevant personal data processing information;
2. the Whistleblower must expressly communicate their desire to benefit from the Whistleblowing protections;
3. the meeting must take place in a suitable location to ensure the confidentiality of the Whistleblower and within a reasonable timeframe (within 15 working days);
4. the Whistleblowing Report Manager will document the content of the Report through a verbal report (which the Whistleblower can verify, rectify, and confirm by signing), updating the relevant Whistleblowing Report Register.

In addition, it is possible to submit the Report in written form by mail. In this case, the sealed envelope must bear the inscription on the outside “reserved for the Whistleblowing Report Manager” at:

Boglioli Spa
Via Brescia, 47
25020 Gambara (BS)

thus expressing the willingness to benefit from the Whistleblowing protections.

If the Report is not anonymous, it must be sent in a double sealed envelope: the first with the identifying data of the Whistleblower (together with a photocopy of the identification document), the second with the report, in order to separate the identifying data of the whistleblower from the report. Both envelopes must then be placed in a third sealed envelope bearing on the outside the inscription “reserved for the Whistleblowing Report Manager”.

Reference to the Regulations

For all matters not expressly regulated in this document, reference is made to Legislative Decree 24/2023 and the related Regulations for the management of whistleblowing reports already adopted by the Management Bodies of the Companies.