REPORTING OFFENCES – WHISTLEBLOWING

SODECIA Group is committed to the highest standards of transparency, integrity and compliance with legal requirements. In accordance with the applicable law, including Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, and the respective national transpositions, SODECIA has established an internal whistleblowing channel to enable the reporting of offences.

How to Report an Offence

If you wish to report an offence or an irregularity that you have become aware of during your professional activity with the SODECIA Group, you may submit your report by email to the following dedicated address:

whistleblowingquestions@sodecia.com

Your report should include, to the extent possible, the following information: a description of the offence or irregularity; the date and place of occurrence; the identity of the person(s) involved (if known); any supporting documentation or evidence.

Anonymous Reporting

You may submit your report anonymously. SODECIA will investigate all reports, whether anonymous or identified.

Confidentiality and Whistleblower Protection

All reports are treated with strict confidentiality. The identity of the whistleblower, where known, is only disclosed in compliance with a legal obligation or court decision. SODECIA prohibits any act of retaliation against whistleblowers who report in good faith, in accordance with the applicable whistleblower protection legislation.

Handling of Reports

Upon receipt of a report, SODECIA Group will acknowledge receipt within 7 days (where the whistleblower has provided contact details) and will inform the whistleblower of the measures planned or adopted within a maximum period of 3 months from the date of receipt. Reports are handled in accordance with SODECIA’s internal Procedure for Reporting Offences and Protecting Whistleblowers (GG-GV-PR003).

What May Be Reported

Reports may concern offences related to, among others: public procurement; financial services and prevention of money laundering; product safety; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety; public health; consumer protection; privacy and personal data protection; corruption; child labour; human trafficking; discrimination; harassment; health and safety conditions; unethical business practices; and protection against retaliation.

Who May Report

Reports may be submitted by any natural person who has become aware of an offence during their professional activity, including current and former employees, service providers, contractors, subcontractors, suppliers, clients, shareholders, members of management and supervisory bodies, volunteers and interns.

External Reporting Channels

Under certain circumstances defined by law, whistleblowers may also report offences to competent external authorities, including criminal police bodies, independent administrative authorities, public institutes, general inspections and local authorities.

Data Protection

Personal data collected in the context of whistleblowing reports is processed in accordance with the General Data Protection Regulation (EU) 2016/679 and applicable national data protection legislation. Reports are retained for a minimum period of five years.