Whistleblowing (Reports 37001)

Welcome to the Crime Prevention section of VM Group Srl

In particular, corruption is a bad habit that does not specifically concern any single country or single sectors of the economy and carries a series of negative implications both from a legal standpoint, as it is a crime, and from a social standpoint.

VM Group Srl intends to actively contribute to the fight against corruption by adopting a Corruption Prevention Management System in accordance with the requirements of the UNI ISO 37001:2016 standard and by committing its leadership to creating a culture based on integrity, transparency, honesty, and compliance with the law.

The Corruption Prevention Management System implemented by VM Group is a set of activities designed and implemented with an integrated and synergistic approach, aimed at continuously improving performance and reducing corruption risks.

VM Group, in fact, has adopted and implemented for years an Organization, Management and Control model in compliance with the provisions of the UNI EN ISO 37001:2016 standard with the related Code of Ethics and Disciplinary System, which can be downloaded from our website.

To monitor the correct implementation of the Anti-Corruption Management System, the Anti-Corruption Compliance Function has been appointed. You can contact the function via the following email address: anticorruzione@vmgroupsrl.com .

VM Group Srl has defined its own Policy regarding the Prevention of Corruption, which includes:

Strict and full compliance with current legislation regarding the prevention and fight against corruption, in Italy and in any country where VM Group Srl operates;
The absolute prohibition on engaging in behavior that could be considered corruption or attempted corruption;
The identification, within the scope of one's activities, of areas of potential risk and the identification and implementation of appropriate actions to reduce/minimize these risks;
The commitment to plan and implement one's policies and actions in such a way as not to be involved in any way in corrupt situations or attempts and not to risk involvement in illicit situations with public or private entities;
Raising awareness among business partners so that they adopt, in their specific areas of expertise, policies and actions to prevent corruption;
Raising awareness and training employees and managers on corruption prevention issues;
Methods of reporting, via the web, unlawful conduct or violations of the Anti-Corruption Policy, directly to the Anti-Corruption Compliance Function, suspicions in good faith, or on the basis of reasonable belief, without fear of retaliation;
The presence of a compliance function for the prevention of corruption, which is guaranteed full authority and independence;
Commitment to continuously improving anti-corruption prevention activities, thanks to the monitoring activities established within the Anti-Corruption Management System implemented in accordance with the UNI ISO 37001:2016 standard.

PAC 03 Procedure

reporting suspicious activity

Code of Ethics and

behavior

FORM FOR REPORTING ILLEGAL CONDUCT

Mod SI ed 02 rev 0 of 01/06/2023

(cd whistleblower)

name and surname (optional)

place of employment

E-mail

Telephone

date/period in which the event occurred

qualification and functional position

place where the event occurred

Office/Company Headquarters

Exterior of the Office/Headquarters

place and address

I BELIEVE THAT THE ACTIONS/OMISSIONS COMMITTED/ATTEMPTED ARE (The report does not concern the whistleblower's personal grievances or requests pertaining to employment regulations or relationships with superiors or colleagues.

Criminally relevant.

Carried out in violation of the Code of Ethics, protocols, procedures and/or principles of conduct and other provisions subject to disciplinary action.

Carried out in violation of the Anti-Corruption Policy which is part of the UNI ISO 37001:2016 Anti-Corruption Management System.

Likely to cause financial damage to the company to which they belong or to another private and/or public entity.

Likely to cause damage to the image of the Company or to another private and/or public entity.

Other (please specify)

specify

PERSON(S) OF THE ACT (Enter personal details if known or any other information suitable for identification)

CLEAR DESCRIPTION OF THE FACT (conduct and event)

OTHER POSSIBLE PARTIES WITH KNOWLEDGE OF THE FACTS AND/OR ABLE TO REPORT THEM (Insert personal details, if known, for each element suitable for identification)

ANY ATTACHMENTS TO SUPPORT THE REPORT

place and date

NB: Employees and collaborators who wish to report unlawful conduct (material corruption cases according to UNI ISO 37001:2016) and other crimes against public administration, alleged damage to public funds, or other administrative offenses of which they have become aware within the Company must use this form. Please remember that the legal system protects those who report unlawful conduct.

In the event that there is a reasonable belief regarding the existence of attempted, alleged, or actual corrupt acts, or any violation or deficiency concerning the UNI ISO 37001:2016 Corruption Prevention Management System, the above-mentioned individuals must promptly inform the Anti-Corruption Officer.

This obligation to provide information also applies to the Company's external collaborators by express contractual provision.

To this end, the Company provides its employees and/or collaborators with specific reporting channels and/or technical platforms that promote the protection of the data of the whistleblower in good faith, the reported individual, and third parties.

The protection of the reported individual's identity will no longer apply if reports are clearly unfounded and deliberately pre-arranged with the aim of harming the reported individual and/or the company.

PRIVACY

I declare that I am at least 18 years old, that I have read the privacy policy (https://www.vmgroupsrl.com/informativa-sulla-privacy) and I consent to the processing of my personal data in accordance with the new GDPR EU 2016/679 Regulation