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Whistleblowing – Reporting procedure

In the Whistleblowing section of the Comac S.p.A. website, the company has opted to provide a tool for anyone who wishes to report, in good faith, unlawful conduct, whether commissive or omissive, which may constitute a violation of or inducement to violate the Code of Ethics, Organisation, and Management and Control Model pursuant to Italian Leg. Decree 231/01, adopted by the company, and the related implementing documentation, and company rules.

ACCEPTANCE OF REPORTS

Comac S.p.A welcomes reports even if provided anonymously, thereby demonstrating a commitment to transparency and openness. However, the Company will vigorously pursue anyone who submits reports in bad faith, with intent to defame or that do not respect the spirit of corporate collaboration.

Reports must be aimed at protecting the integrity of the Company and must be detailed, based on precise and consistent facts. It is essential that they are presented in a responsible manner, geared towards the common good, and fall within the categories of non-compliance for which the whistleblowing system has been implemented.

Comac S.p.A requests that situations, that do not fall under the above-mentioned cases, not be reported. In general, the company encourages employees to resolve any labour disputes through dialogue, even informally, with colleagues, direct supervisors or the relevant company departments. Open collaboration contributes to maintaining a healthy and cohesive working environment.

HOW TO SUBMIT A REPORT

Reports can be submitted using one of the following methods:

Reports sent through the electronic whistleblowing procedure are handled directly by Comac S.p.A’s Supervisory Board. These professionals deal with reports in compliance with the confidentiality principles laid down in the company’s Whistleblowing Policy and check their validity according to the procedures indicated.

PROTECTION AND RESPONSIBILITY

Comac S.p.A. guarantees the full protection of the Whistleblower, preventing any form of retaliation or discrimination, whether direct or indirect, against anyone who submits a report, in good faith. When reporting is done through the Whistleblowing computerised procedure, the anonymity of the whistleblower is guaranteed, unless the whistleblower explicitly consents to disclosure, and without prejudice to legal obligations.

To preserve the integrity of the whistleblowing process, sanctions are imposed on anyone who violates the whistleblower protection measures. Furthermore, if reports, made with malice or gross negligence, prove to be false, unfounded or with defamatory intent, the Company reserves the right to apply sanctions against the whistleblower, where possible. These sanctions may include appropriate legal action to safeguard the interest of the Company, the persons involved or entities affected by the report.

PROTECTION OF THE PERSON REPORTED

While the potential non-conformities are investigated and assessed, the individuals involved in the reports may be informed or involved in such activity. However, it is important to stress that the initiation of proceedings will not be based solely on the report itself, unless concrete evidence emerges regarding its content.

The initiation of proceedings may occur following the discovery of further evidence, which is duly corroborated and verified, and based on the initial report.

PRIVACY

The report will be acknowledged and managed by the company’s Supervisory Body. Any personal or sensitive data included in reports, including data relating to the identity of the whistleblower or of other individuals, will be processed in accordance with current data protection regulations.

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