CMA macchine per caffè S.r.l. takes great care to ensure that its activities and business are conducted with integrity and in compliance with the law.

“Whistleblowing" means any report made by employees or third parties (e.g. partners, suppliers, customers, collaborators and stakeholders in general) on conduct occurring in the work context or affecting it, which relates to employees and/or third parties and which involves a violation of laws, regulations, rules and procedures in force in the Company.

In order to reinforce its commitment to conduct its business with the utmost integrity and honesty, the Company has complied with the regulations on whistleblowing and has made available to its stakeholders a reporting system that allows them to make the above-mentioned reports, with the utmost respect for the confidentiality of the reporter, in accordance with the provisions of Legislative Decree no. 24 dated 10 March 2023 ("Implementation of EU Directive 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law and on the protection of persons who report breaches of national laws").

Reports may relate to information obtained in the course of work concerning potential or actual violations, or conduct designed to conceal violations, of any of the following:

i) administrative, accounting, civil and criminal offences prejudicial to the interests, propriety and integrity of the Company;
ii) unlawful conduct within the meaning of Legislative Decree 231/2001 or violations of the 231 Model, the internal procedures relevant to the 231 Model and the Code of Ethics, where they exist;
iii) offences falling within the scope of application of Community legislation relating to public procurement, services, products and financial markets, the prevention of money laundering and terrorist financing, product safety and conformity, transport safety, environmental protection, radiation and nuclear safety, food and feed safety and animal health and welfare, public health, consumer protection and the protection of personal data, and the security of networks and information systems;
iv) acts or omissions affecting the financial interests of the European Union;
v) acts or omissions affecting the internal market.

On the other hand, whistleblowing reports do not include disputes, claims or requests relating to a personal interest of the whistleblower, which relate exclusively to his or her individual employment relationship or to his or her relationship with superior figures, or communications or complaints relating to activities of a commercial or service nature to the outside world.

The report must be made in good faith and must be complete, including all elements known to the reporting party, in order to allow a proper verification of the validity of the reported facts.

The Company will guarantee the confidentiality of the whistleblower, regardless of the reporting method chosen, and will treat all information confidentially and in accordance with applicable regulations.

In accordance with the provisions of the Whistleblowing Policy adopted and published on the Company's notice board, the Company has established a "Whistleblowing Committee", consisting of the Human Resources Manager and a trusted lawyer, which is formally authorised to process personal data that may be included in the reports in accordance with EU Regulation 2016/679 (the so-called "GDPR"), and has provided a whistleblowing model, which is also published on the notice board.

Reports of unlawful conduct as described above can be made by anyone, employees and third parties, in good faith and without fear of retaliation, using the following methods and channels:

- in writing, either by filling in the reporting form, which can be sent by post, marked "Personal Confidentiality", to the "Reporting Committee", for the attention of the Chairman of the Reporting Committee, at CMA macchine per caffè S.r.l., Via Condotti Bardini, 1, 31058 Susegana (TV), or by using IT tools, by sending the completed reporting form by e-mail at whistleblowing@cmamc.it;
- at the specific request of the reporter, through direct meetings with the Reporting Committee.

To make an appointment with the Whistleblowing Committee or to receive the relevant documents, including the Guidelines and the Reporting Form, you can also contact the Whistleblowing Committee directly at the Company or by e-mail at whistleblowing@cmamc.it.

Cod.Fisc/P.IVA 04518950268

Via Condotti Bardini, 1
31058 Susegana (TV) | Italy

Phone +39 0438 6615
Fax +39 0438 60657
E-mail info@cmamc.it

Management and coordination: RYOMA MC SPA