Whistleblowing – Reporting unlawful conduct (Italy)

Swan promotes a corporate culture based on integrity, ethics, and compliance. In line with Legislative Decree 24/2023, anyone who becomes aware of unlawful conduct or breaches of internal or external rules may submit a report, including anonymously, through secure and confidential channels.‍

‍Who can submit a report

‍Reports may be submitted by anyone who has (or has had) a relationship with Swan, including:
• employees, including during recruitment or after the employment relationship ends;
• collaborators, consultants, self-employed workers, and suppliers;
• volunteers and interns, paid or unpaid;
• shareholders and equity holders;
• members of the Board of Directors and other control or supervisory bodies;
• individuals who hold management, director, or representative roles, including in practice.

‍What can be reported

‍Reports may relate, by way of example, to:
• breaches of Italian or EU laws, regulations, or rules;
• unlawful conduct related to anti-money laundering, data protection, security, or workplace health and safety;
• corruption, fraud, abuse of power, discrimination, or harassment;
• breaches of the Code of Ethics or internal procedures;
• conflicts of interest.

‍How to submit a report (available channels)

‍Dedicated email
You can also submit a report by email by writing to wb@swan.io. The reporting person must specify that the communication falls within the scope of whistleblowing, in order to benefit from the protections provided by law.

‍Protections and confidentiality

‍Swan guarantees:
• protection of the reporting person’s identity and of the individuals involved;
• protection against retaliation, threats, or discrimination;
• the possibility to submit a report anonymously;
• compliance with EU Regulation 2016/679 (GDPR) for all processed data.

‍Timelines and report handling

‍• You will receive confirmation of receipt within 7 days.
• You will receive an update on the outcome within 3 months.
• Reports are handled by the Whistleblowing Officer, who may involve, if necessary, a committee or other control bodies, always ensuring the highest level of confidentiality.

‍External reports (ANAC)

‍If the internal channel is not available, or if its use is considered to carry a risk of retaliation, a report may also be submitted to the National Anti-Corruption Authority (ANAC), following the instructions available at: 🔗 www.anticorruzione.it‍

‍Information on personal data processing

‍All personal data provided in the context of whistleblowing is processed in accordance with the GDPR and applicable Italian law, solely for the handling of the report and in accordance with the principles of necessity, data minimization, and limited retention.mitata.