Internal Alert Procedure of the Sella group companies

The "Internal Alert Procedure", also known as "whistleblowing", is a tool for preventing and rectifying acts or events that may constitute unlawful conduct under external and internal regulations (such as the Code of Conduct or the Self-discipline Code), harmful to the public interest or the integrity of the private entity. It encourages and protects positive behavior by employees or other authorized individuals identified by the regulations who, upon becoming aware of the unlawfulness or impropriety of the actions of another party in the workplace, decide to confidentially report such acts or events to the relevant authorities.

An effective whistleblowing system is an important tool for the Group in consistently upholding the standards of transparency and integrity in its actions, serving as a useful alarm bell that allows for the adoption of appropriate measures.

Who can submit reports

Reports can be submitted to the internal alert procedure by employees and by those who work in any capacity based on relationships that involve their inclusion or connection with the company organization, even in a form different from an employment relationship, such as:

• Self-employed workers, external workers and collaborators, freelancers and consultants who carry out their work at the Group;
• Paid and unpaid volunteers and interns;
• Shareholders and people with administrative, management, control, supervisory or representative functions;
• Staff of suppliers external to the Group.

What may be reported

Reports may concern any act or fact that may constitute a violation of the external rules governing the activity undertaken (banking activities pursuant to the Consolidated Banking Act (TUB) and the provision of investment services in accordance with the Consolidated Law on Finance, as well as those relating to the distribution of insurance products), and of the Group's internal rules. Reports may also relate to offences under Legislative Decree 24/2023 (such as environmental protection, public procurement, protection of privacy, protection of personal data, network and information system security, etc.), potential or actual breaches of the provisions laid down to prevent money laundering and the financing of terrorism as specified in Article 48 of Legislative Decree 231/2007, any other unlawful conduct under Legislative Decree 231/01, and any breach of the organisational model adopted by the Company. The report may also concern any act or fact that may constitute a violation of antitrust legislation (Law No. 287 of 10 October 1990 - Rules for the protection of competition and the market).

The Group safeguards the whistleblower 'against retaliatory, discriminatory, or otherwise unfair actions resulting from the report,' in an environment that respects the dignity of the whistleblower.

How to submit reports

Reports can be submitted in written form, verbally, or through a direct meeting via the dedicated online procedure available at the following link: https://www.mygovernance.it/whistleblowing-gruppo-sella/.

The whistleblower is also entitled to use the external communication channel established by the ANAC, when one of the following conditions is met:

• the internal channel has been used beforehand, but there has been no response nor follow up within the prescribed time limits;
• there is an ‘imminent and manifest danger to the public interest’.
• internal channels have not been used due to risk of retaliation or ineffectiveness of those systems.