WEB NOTICE ON THE WHISTLEBLOWING PROCEDURE

RBR Immobiliare srl encourages ethical and transparent behaviour and would like to thank those who help ensure internal compliance with its whistleblowing procedure.
Through a resolution by its Board of Directors, the Company has adopted a specific Whistleblowing procedure pursuant to Italian Legislative Decree 24/2023.

1. What is Whistleblowing?

Whistleblowing is when individuals, while carrying out their jobs, become aware of offences committed at the workplace and then report what has happened in order to stop any wrongdoing.
In fact, active and responsible participation from employees and third parties by reporting any potential conduct that does not comply with work ethics or existing legislation helps the company to identify any potential issues and to promptly take any necessary corrective measures, preventing the risk of crimes and economic or reputational damage.

2. Who are whistleblowers?

Whistleblowers are anyone who can submit a report: employees, former employees, job applicants, interns, partners, clients, suppliers, consultants, contractors, shareholders and, more generally speaking, anyone connected to the company’s business.

3. Subject of the whistleblowing

Whistleblowing can generally involve breaches of European law, as well as the transposing Italian law, including offences that damage the Union’s financial interests or that involve the internal market, competition and State aid or corporation tax offences. Furthermore, any breaches of Italian Legislative Decree 231/2001, the Company’s 231 Model and its Code of Ethics can be reported.
A whistleblowing report must be adequately substantiated, i.e. it must contain sufficient details to allow the reported events to be verified (e.g. elements that help identify the individuals involved, the context, the location and the timeframe of the reported events accompanied by all the supporting documentation which the whistleblower has readily available).
Whistleblowing channels may not be used for business complaints or for disputes and claims linked to purely personal interests.
Reports must be based on justified suspicions and factual evidence; if the whistleblower acts in bad faith, disciplinary measures may be taken against the whistleblower.

4. Whistleblowing methods

Management of the reporting channel is entrusted to a whistleblowing committee formed of two independent external consultants – the Lawyers Gino Bottiglioni and Stefano Bruno – who have been selected to ensure impartiality, confidentiality and competency in handling any reports received.
A whistleblowing report can be made by:

• post c/o Studio Legale BRB, to the address Via Dal Luzzo, n.3 40125, Bologna (BO), writing “alla cortese attenzione del Comitato di gestione delle segnalazioni” (for the attention of the Whistleblowing Committee), specifying the name of the group’s company where the alleged breach took place, and clearly adding the word “riservata” (confidential) on the envelope;
• face-to-face meeting with the whistleblowing committee in order to make an oral report, by sending a request by e-mail to the dedicated address wbsegnalazioni@iporticihotel.com, specifying:

1. 1. an address to be contacted confidentially;
   2. your availability for a meeting;
   3. preferences for the communication channel (e.g. in-person meeting, video call, etc.)

5. Confidentiality

Confidentiality is guaranteed for the identity of the whistleblower, the person involved and the person mentioned in the report, as well as for the content of the report and the relative documentation, in accordance with the rules provided for by the GDPR and the Privacy Code.
This does not include cases involving responsibility for libel or slander pursuant to the provisions of the Italian Penal Code or of Article 2043 of the Italian Civil Code, as well as cases where anonymity cannot be legally enforced (i.e. criminal, tax or administrative investigations, supervisory body inspections, etc.).

6. Prohibition of retaliation

Any form of personal or professional retaliation due to whistleblowing is prohibited. If you believe you have suffered any discrimination or retaliation due to whistleblowing, you can report it to the Italian National Anti-Corruption Authority (ANAC).
Any retaliation allegedly suffered must be connected to the whistleblowing report made.