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Whistleblowing protection policy

Version 1.0 - June 2025

1. Purpose and objectives

Tangible Srl SB is committed to promoting maximum integrity, transparency and legality in all business activities. This policy establishes a protection system for those who report legal violations, financial irregularities, illegal conduct or other serious violations.

This document complies with Italian legislation (D.Lgs. 24/2023) and EU Directive (2019/1937) on the protection of persons who report violations of Union law and guarantees protection from retaliation for all reporters.

2. Scope of application

This policy applies to:

  • all employees, collaborators and consultants of Tangible
  • former employees for violations learned during the employment relationship
  • candidates during the selection process
  • suppliers, customers and business partners
  • any third party who becomes aware of serious violations

The protection system covers all phases of the relationship: pre-contractual, contractual and post-contractual.

3. Types of reportable violations

The whistleblowing system handles reports relating to:

  • violations of national and European laws
  • financial irregularities, fraud and corruption
  • workplace safety and environmental protection violations
  • discrimination, harassment and abuse
  • conflicts of interest and unethical behavior
  • violations of Model 231 and the Corporate Code of Ethics
  • threats to public health and safety
  • personal data protection violations

4. Reporting channels

4.1 Internal channels

4.2 Anonymity guarantees

  • Completely anonymous reports guaranteed
  • Option to provide contacts for feedback (optional)
  • Absolute protection of identity when requested
  • Reference code system for anonymous follow-ups

4.3 External channels

  • ANAC (National Anti-Corruption Authority) for external reports
  • Judicial authorities for criminal offenses
  • Public disclosure in cases of imminent danger to public interest

5. Management process

5.1 Receipt and registration

  • All reports received by dedicated team (whistleblowing@tangible.is)
  • Immediate registration and assignment of reference code
  • Separation of identifying data from report content

5.2 Assessment and investigation

  • Preliminary examination within 7 days of receipt
  • Start of thorough investigation within 30 days
  • Involvement of external experts when necessary
  • Maintenance of maximum confidentiality

5.3 Resolution and feedback

  • Process completion within 90 days of receipt
  • Communication of outcome to reporter (if contacts provided)
  • Implementation of corrective and preventive actions
  • Monitoring of effectiveness of adopted measures

6. Reporter protection

6.1 Identity protection

  • Absolute prohibition on revealing reporter's identity
  • Access to information limited to authorized personnel only
  • Secure data storage in compliance with GDPR

6.2 Prohibition of retaliation

  • Tangible prohibits any form of retaliation according to art. 6 of D.Lgs. 24/2023
  • Protection from dismissals, demotions, mobbing
  • Nullity of retaliatory acts and right to compensation
  • Monitoring of reporter's work situation for 2 years

6.3 Legal and psychological support

  • Free legal assistance for reporters who suffer retaliation
  • Psychological support to manage reporting stress
  • Protected and confidential communication channels

7. Retaliation management

7.1 Prevention

  • Periodic training for all personnel
  • Corporate culture based on integrity and transparency
  • Proactive monitoring to identify potential retaliation

7.2 Case management

  • Immediate procedure for retaliation reports
  • Reporting to ANAC for legal verification
  • Immediate disciplinary action against those who implement retaliation

8. Response times and guarantees

8.1 Guaranteed timelines

  • Receipt confirmation: within 7 days
  • Investigation start: within 30 days
  • Feedback to reporter: within 90 days
  • Follow-up on implemented actions: within 120 days

8.2 Urgent cases

  • Accelerated procedure for violations constituting imminent danger
  • Immediate involvement of competent authorities
  • Timely communication to reporter of actions taken

9. Training and awareness

9.1 Training programs

  • Mandatory training for all employees
  • Periodic updates on whistleblowing legislation
  • Awareness of reporters' rights and duties

9.2 Internal communication

  • Regular communications on reporting channels
  • Publication of (anonymous) success case studies
  • Promotion of a "speak up" culture

10. Reporting and transparency

10.1 Annual report

  • Publication of aggregated reporting statistics
  • Analysis of most frequent types of violations
  • Reporting of implemented corrective actions
  • System effectiveness indicators

10.2 Periodic reviews

  • Semi-annual review of system effectiveness
  • Procedure updates based on best practices
  • Consultation with external experts for improvements

11. Contacts

Whistleblowing team: whistleblowing@tangible.is
Online Form: https://tangible.is/en/code-of-ethics
ANAC (External Reports): https://www.anticorruzione.it/-/whistleblowing

12. Entry into force

This policy enters into force from June 30, 2025 and is subject to periodic reviews to ensure regulatory compliance and operational effectiveness.

Approved by the Board of Directors on: June 30, 2025