PLC S.p.A. adopted a first version of the Risk organization, management and control model on 14 March 2011, which was then updated on 24 May 2016.

Subsequently PLC S.p.A., both due to the organizational changes resulting from its corporate restructuring and also as a result of the introduction of further types of offenses within the scope of Legislative Decree 231/01, has updated and integrated its organization model, risk management and control first by resolution of the Board of Directors on 11 October 2019 and, most recently, on 26 January 2022.

In particular, the organization, management and control model of PLC S.p.A. is made up by:

• a “General Part”, which contains the key principles of the Model itself;
• a “Special Part”, containing the indication of the areas at risk of crime identified and the description of the preventive controls implemented by PLC S.p.A. in order to prevent the commission of the crimes envisaged by Legislative Decree 231/01 deemed relevant, as well as an illustration of the rules of conduct of a general nature, implemented by PLC S.p.A. for each category of offenses.

In order to facilitate the supervision of the effectiveness of the organization, management and control model, in compliance with the law in force, PLC S.p.A. has provided that any violation or suspected violation of Model 231/01 and / or any other information relating to the implementation of the organization, management and control model can be reported, in compliance with the provisions of current legislation, to the Supervisory Body, through the following reporting channels:

• by email to the following address: odv.plc@gmail.com;
• in paper form to the following address: PLC S.p.A. Via Lanzone 31, 20123 – Milan, in a sealed envelope for the kind attention of the Supervisory Body.

The PLC Group has always been particularly attentive to the prevention of risks that could compromise the responsible and sustainable management of its business. For this reason, PLC S.p.A. has prepared the procedure on “whistleblowing” (“Procedure”) for its employees and third parties.

Whistleblowing is the reporting system with which anyone who wishes can contribute to the emergence of risks and / or situations potentially prejudicial to PLC S.p.A. such as a fraud, a generic risk or a potentially dangerous situation, by sending a specific report.

The ultimate purpose of whistleblowing is to manage any reports in order to identify any problems that could derive from a significant corporate offense pursuant to Legislative Decree 231/01.

The Procedure was approved by the Board of Directors of PLC S.p.A. and regulates, also through operational indications, the process of sending, receiving, analyzing, processing and managing reports of illegal conduct, relevant pursuant to Legislative Decree 231/01, as well as the violations of the relative 231/01 Model, transmitted by the whistleblower. The Procedure also governs the forms of protection of the confidentiality of the whistleblower, protected from any retaliation for having made the report.

The Procedure applies to any report made by any person (employee of PLC S.p.A. or a third party with respect to it) through the appropriate communication channels indicated below, which guarantee its confidentiality.

Reports must be made in good faith and can be made anonymous; in the latter case, the report must be adequately detailed and detailed.

The Supervisory Body of PLC S.p.A. is responsible for managing reports, through the following reporting channels:

• by email to the following address: whistleblowing.odv.plc.spa@gmail.com;
• in paper form to the following address: PLC S.p.A. Via Lanzone 31, 20123 – Milan, in a sealed envelope for the kind attention of the Supervisory Body.

The Procedure falls within the scope of the internal control and risk management system tools adopted by the PLC group to combat corruption, ensure fairness and transparency in the conduct of business and activities, and protect its position and reputation.

Whistleblowing therefore represents a further and important element of the PLC group’s internal control and risk management system.