REPORT MANAGEMENT PROCEDURE COMPLIANT WITH
THE PROVISIONS OF LEGISLATIVE DECREE No. 24 OF 10
March 2023 (WHISTLEBLOWING)

Revision n. 00
Revision no. 01

Approved by the Board of
Directors
Approved by the Board of
Directors

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on 15.06.2023
on 08.08.2023

TABLE OF CONTENTS

1.

DEFINITIONS AND ACRONYMS ..................................................................................32.

DESCRIPTION OF THE PROCEDURE .........................................................................43.

REGULATORY FRAMEWORK .....................................................................................54.

PERSONS WHO MAY MAKE REPORTS ......................................................................55.

SUBJECT OF THE REPORTS........................................................................................6

5.1 BASIC CONTENT OF THE REPORT ............................................................................7
6.

TYPES OF REPORTING .................................................................................................8

6.1

INTERNAL REPORTING...............................................................................................8

6.2 EXTERNAL REPORTING............................................................................................11
6.3 PUBLIC DISCLOSURE ................................................................................................12
7.

FORMS OF PROTECTION FOR THE WHISTLEBLOWER .......................................13

7.1 CONFIDENTIALITY OF THE WHISTLEBLOWER'S IDENTITY .............................13
7.2 PROHIBITION OF "RETALIATION" .........................................................................14
8.

SANCTION SYSTEM.....................................................................................................16

9.

RECORD KEEPING......................................................................................................17

10. AVAILABILITY OF THE PROCEDURE DOCUMENTATION ...................................17
11. UPDATING THE PROCEDURE ...................................................................................18

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1.

DEFINITIONS AND ACRONYMS"ANAC": Italian National Anti-Corruption Authority.
"MISSONI" and/or the "Company": Missoni S.p.A.;"Code of Ethics": the Code of Ethics of the Missoni Group;"Work context": the work or professional activities, present or past, carried out within theframework of the relationships referred to in articles 4 and 7.2, letter c) of the Policy, throughwhich, regardless of the nature of such activities, a person acquires information on violations andwithin which he/she could risk retaliation in the event of making a report or public disclosure orcomplaint to the judicial or accounting authority;"Decree 231": Legislative Decree no. 231 of 8 June 2001 and subsequent amendments andadditions;"Whistleblowing Law": Legislative Decree no. 24 of 10 March 2023;"Model 231": the organisation, management and control model provided for by Decree 231 andadopted by Missoni S.p.A.;"Privacy Policy": Regulation (EU) 2016/679 and Legislative Decree no. 196 of 30 June 2003.
"Supervisory Body or SB": the Supervisory Body established pursuant to Decree 231/2001, theindividual members;"Person involved": the natural or legal person mentioned in the internal or external report or in
the public disclosure as the person to whom the violation is attributed or as a person involved in
the violation reported or publicly disclosed;"Procedure": this procedure;"Retaliation": any behaviour, act or omission, even if only attempted or threatened, carried out
as a result of the report, complaint to the judicial or accounting authority, or public disclosure,and that causes or may cause, both directly and indirectly, unjust damage to the reporting personor the person who filed the complaint;"Report (s)": communication of violations according to the definitions and through the use of thechannels referred to in the Whistleblowing Law;
"Report (s) 231": communication of violations referred to in article 5, no. 1) of the Procedure;

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"Reporting (s) of violations of European Union provisions": communication of the violations
referred to in article 5, no. 2), 3) and 4) of the Procedure;"Reporting party" and/or "Whistleblower": the natural person, among those indicated in Article
4 of this Procedure, who makes the report;"Follow-up": the action taken by the person entrusted with management of the reporting channel
to verify the existence of the reported facts, the outcome of the investigations and any measures
adopted;"Violation (s)": conduct, acts and omissions concerning the matters indicated in article 5 of thisProcedure.

2.

DESCRIPTION OF THE PROCEDURE

The purpose of the Procedure is to regulate and discipline the methods of communication andmanagement of reports concerning violations of national regulatory provisions and violations ofEU regulatory provisions, which harm the public interest or the integrity of MISSONI, of which
the subjects identified below have become aware within the Company's work context, in order toensure that all appropriate actions are taken and all measures implemented to address theviolations reported and, consequently, to avoid their recurrence. In particular, the Proceduretransposes the provisions of Legislative Decree no. 24 of 10 March 2023, containing"Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council of
23 October 2019 on the protection of persons who report breaches of Union law and containing
provisions concerning the protection of persons who report violations of national regulatory
provisions".
This tool is aimed at preventing the emergence of irregularities within the organisation bypromptly intercepting divergent behaviour in order to remedy it, but also to involve senior
management, employees and anyone in a relationship based on interest with MISSONI, in aneffort to combat non-compliance through active and responsible participation.
To this end, the Procedure sets out, in accordance with the Whistleblowing Law, to define thefollowing operational aspects:-

Identification of individuals/entities who can make the reports;-

Identification of the subject of the reports and their basic content;-

Identification of the different forms of reporting and related channels;-

Identification of the recipient of internal reports;

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Indication of the methods used to make the reports;-

Indication of management methods for internal reports;-

Indication of forms of protection for the whistleblower.

3. REGULATORYFRAMEWORK

The term "whistleblowing" refers to the legal provision aimed, on one hand, at defining themethods of reporting illegal conduct in a given context (such as work) and, on the other, at
protecting the reporting party from possible retaliation.
The Whistleblowing Law has transposed into the Italian legal system Directive (EU) 2019/1937of the European Parliament and of the Council, of 23 October 2019, concerning the protection of
persons who report breaches of Union law and containing provisions concerning the protectionof persons who report violations of national regulatory provisions, introducing a "generalised"institution for reporting violations of national and European Union regulations that harm thepublic interest or the integrity of the public administration or private body, of which the persons
referred to in article 3 of the Whistleblowing Law have become aware in a public or private work
context.
This legislation replaces and repeals the previous discipline provided for in Article 54-bis ofLegislative Decree no. 165 of 30 March 2001, Article 3 of Law no. 179 of 30 November 2017
and Article 6, paragraphs 2-ter and 2-quater, of Legislative Decree no. 231 of 8 June 2001, which,respectively in the public and private spheres, limited the subject of the reports to irregularities in
the management or organisation of the activity of an institution, to the extent that suchirregularities constituted episodes of so-called Maladministration (especially in the public sector)
or violations of the organisational model and/or the code of ethics, as well as circumscribing thecategories of whistleblowers and the reporting channels.
The Whistleblowing Law expands the subject of reports, and extends the category ofwhistleblowers to whom the protections provided for therein apply; identifies three reporting
channels; specifies the methods to be used for handling reports; regulates the identification of therecipient of reports; and provides for a specific sanctioning regime, which punishes, inter alia,
entities that do not have a "compliant" reporting system with the relative regulation.
4.

PERSONS WHO MAY MAKE REPORTS

Reports can be made by the following persons:•

employees of MISSONI S.p.A., also during the probationary period;5•self-employed workers, individual entrepreneurs, collaborators with whom MISSONI S.p.A.
has relationships for the provision of services, the execution of works, the supply of goods;•

the holders of an agency agreement, commercial representation agreement and otherrelationships of continuous and coordinated collaboration, according to the pro tempore laws
in force, who carry out their work at MISSONI S.p.A.;•

workers or collaborators, who carry out their work at legal entities, who provide goods orservices or carry out works for MISSONI S.p.A.;•

freelancers and consultants who provide services for MISSONI S.p.A.;•

volunteers and trainees, both paid and unpaid, who work at MISSONI S.p.A.;•

the shareholders of MISSONI S.p.A.;•

the directors and statutory auditors, and the auditing company of MISSONI S.p.A., or any
person who de facto exercises functions of administration, direction, control and supervisionat MISSONI S.P.A.

In addition, the report can also be made:a) when the legal relationship with the Company has not yet started, if the information on theviolations was acquired during the selection process or at other pre-contractual stages;b) after the termination of the employment relationship with MISSONI, if the information on
the violations was acquired during the course of the work relationship.

5. SUBJECT OF THE REPORTS
Reports may concern violations of national or European Union regulatory provisions that harm
the public interest or the integrity of MISSONI S.p.A., of which the whistleblower has becomeaware within the Company's work context.
Specifically, violations are behaviours, acts or omissions, which consist of:1) relevant unlawful conduct pursuant to Decree 231, or non-compliance with Model 231, theCode of Ethics, and policies and procedures adopted by the Company;
2) offences falling within the scope of the acts of the European Union, in violation of national
and European provisions, relating to the following sectors: public procurement; financial
services, products and markets and prevention of money laundering and terrorist financing;product safety and compliance; transport safety; environmental protection; radiation
protection and nuclear safety; food and feed safety and animal health and welfare; publichealth; consumer protection; protection of privacy and protection of personal data and6security of networks and information systems; acts or behaviours that compromise theinterests protected by the European Union in these sectors are also included;3) acts or omissions that damage or, in any case, compromise the financial interests of theEuropean Union;4) acts or omissions concerning the internal market of the European Union, including breachesof European Union competition and state aid rules, as well as breaches concerning theinternal market of the European Union related to acts that violate corporate tax rules ormechanisms whose purpose is to obtain a tax advantage that defeats the object or purpose of
the applicable corporate tax legislation (and therefore, the use of avoidance mechanisms).
The whistleblowing reports relating to the matters indicated above may also concern wellfounded suspicions concerning violations committed or that, on the basis of concrete elements,
could be committed at MISSONI, as well as information concerning conduct aimed at concealing
such violations.
The following reports are not subject to this Procedure and are not addressed by the provisionsof the Whistleblowing Act: disputes, claims or requests related to a personal interest of the whistleblower, or inherent totheir employment relationships with hierarchically superior figures (such as, for example,
complaints of a personal nature by the whistleblower, a disagreement between two
employees or relationships with the hierarchical superior or with colleagues, or a situationof doubt regarding their job growth prospects and, more generally, claims/requests that fallwithin the discipline of the employment relationship, etc.).
The topics referred to in the previous point must not be reported through the channels described
below. These situations can of course be discussed and addressed through the other available
channels (for example, interviews with the line manager).
It should be noted that any reports that do not concern aspects falling into any of the categories
indicated above will not be considered.
5.1

Basic content of the report

In order to carry out an adequate investigation in this regard, it is essential that the report contains
at least the following elements:•

a clear and complete description of the facts being reported, expressly stating that the reportrefers to MISSONI S.p.A.;•

reference to any documents that may substantiate these facts;7•

if known, the time and place in which the reported facts took place;•

if known, general information or other elements (such as the qualification and service inwhich the activity is carried out) that allow identification of the person involved;•

any other information that may usefully substantiate the reported facts.

Reports made by using the methods provided below (in particular internal reporting), but without
any element that allows their author to be identified (i.e. anonymous reports), will be taken into
consideration provided that they are adequately substantiated, detailed and based on precise andconcordant factual elements (without generic or confusing content), so as to allow evaluation andassessment of the case (for example, the mention of specific company areas, procedures orparticular events, etc.).
In all cases, it is forbidden to:•use insulting language;•

submit reports for purely defamatory or slanderous purposes;•

submit reports relating exclusively to aspects of private life, and having no direct or indirect
association with business activities. Such reports will be considered even more serious when
they involve sexual, religious, political and philosophical habits and beliefs.

6. TYPES OF REPORTING
Depending on the means of communication used, in accordance with the provisions indicatedbelow, the whistleblower may rely on: internal reporting: written or oral communication of information on violations through theuse of the channels referred to in paragraph 6.1;
 external reporting: written or oral communication of information on violations through theuse of the channel referred to in paragraph 6.2;
 public disclosure, providing information about violations in the public domain through the
public press or electronic means, or in any case through communication methods allowing
to reach a large number of people.
In any case, the whistleblower may always report violations to the judicial or accounting
authority.
6.1 Internal reportinga) Recipient of the report8The Recipient of the report is the Supervisory Body of MISSONI S.p.A. (hereinafter the "Channel
Manager").
b) Reporting channels
The channels for making reports are as follows:i) Written communication
 Online portal:
https://areariservata.mygovernance.it/#!/WB/missoni
The portal is managed in full respect of confidentiality rules by a third party independent of
the Company. The Whistleblower must indicate that this is a report relating to the Company.
 Regular mail to be sent to the following address: Mario Ippolito c/o Carnelutti Law Firm –Via Principe Amedeo 3, Milan, 20121. In view of the confidentiality protocol of the reportas handled by the Channel Manager, it is necessary that the report be sent in two closed
envelopes: the first with the identification data of the reporter together with a photocopy ofan identification document; the second with the report, in order to keep separate theidentification data of the reporter from the report itself. Both must then be placed in a thirdclosed envelope bearing the words "Strictly confidential. Reserved to the Channel Manager- whistleblowing", in order to guarantee maximum confidentiality; in the event of use of thischannel, the Whistleblower must indicate in the communication an address / email to which
the Channel Manager can send proof of receipt of the Report and provide all relative
feedback pursuant to article 5 of the Whistleblowing Law, as indicated below.
If no address / email is indicated, the Channel Manager will examine the Report incompliance with the conditions referred to in Article 5 of the Procedure, without any
obligation to send proof the receipt or to give feedback as provided for by the Whistleblowing
Law.
ii) Oral communication
 Direct meeting: the whistleblower, using the above channels, may request a direct meetingwith the Channel Manager, to make the report orally, provided that he/she indicates in therequest a telephone number at which he/she can be contacted. The meeting will be scheduledwithin 15 (fifteen) days of receipt of the request.
With the consent of the whistleblower, oral communication of the report is documented by
the Channel Manager, by recording on a device suitable for storage and listening or by9keeping written minutes. In the event of a written report, the whistleblower may verify,
correct and confirm the meeting report by signing it.
c) Subject of the report
Model 231 reports and reports of violations of European Union provisions may be communicatedthrough internal reporting.
d) Management of the report and outcome of the investigation phase
Following the report, the Channel Manager:•

issues a notice of receipt of the report to the whistleblower within seven days of the date ofreceipt, where possible in accordance with the indications provided above;•issues the Policy on the processing of personal data (according to the Attached document)
to the whistleblower;•holds discussions/maintains communication with the whistleblower and may request
additional information from the latter, if necessary; the discussions/communication andintegrations can take place, at the request of the whistleblower, through the acquisition of
written observations and documents;•

duly follows up on the reports received;•

provides information relating to all follow-up activities carried out or intended to be carriedout regarding the report ("feedback") within three months from the date of the notice ofreceipt or, in the absence of such notice, within three months from the expiry of the sevenday period from submission of the report.

It is understood that proof of receipt and feedback will not be provided in the event of ananonymous report or failure to indicate an address by the whistleblower.
For the purposes of the investigation phase, the Channel Manager may also rely on the support
and collaboration of the competent bodies. In the event that specialist support is necessary(technical, legal, etc.), this activity may also be carried out with the involvement of an external
consultant selected by the Channel Manager. In this case, subject to a commitment to professional
confidentiality, all the documentation necessary to carry out the investigation may be sent to theconsultant.
The report will be considered well-founded where it is inherently plausible, supported bydocumentary evidence or other evidence (such as, for example, precise reference to other persons
who can confirm it).

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The validity of the circumstances represented in the report must, in any case, be assessed, incompliance with the principles of impartiality and confidentiality, by the Channel Manager, whocarries out any activity deemed appropriate, including the hearing of any other persons eligible toprovide information on the reported facts.
At the end of the investigation phase, the Channel Manager, in addition to providing feedback to
the whistleblower, also communicates the outcome to those corporate subjects appointed to takethe appropriate measures in this regard, namely:

the Chief Executive Officer, the HR Manager, the Manager of the structure to which theperson responsible for the established violation belongs (if the person responsible is an
employee or collaborator of MISSONI);the Managing Director, the Manager of the structure with which the person responsible forthe established violation interacts, if the person responsible is a supplier/consultant of
MISSONI;

the Chief Executive Officer, in all other cases, or the Chairman/other director, if the reportconcerns the Chief Executive Officer.

In addition to the above, the outcome of the investigation phase of the report may be
communicated to the Board of Directors of the Company and to the competent bodies so that they
adopt any further measures and/or actions that may be necessary to protect MISSONI in thespecific case.
If, for the purposes of the investigation, it is necessary to reveal the identity of the whistleblower,
the provisions of Article 7.1 below shall apply.
6.2 External reportinga) Conditions for making an external report
The whistleblower may make an external report (relying on the protection provided by the
Whistleblowing Act) if, at the time of its submission, one of the following conditions is met:•

the whistleblower has already made an internal report pursuant to Article 6.1 of theProcedure, which has not been followed up;•

the whistleblower has reasonable grounds to believe that, if he/she made an internal report,
it would not be effectively followed up or that said report may result in a risk of retaliation;•

the whistleblower has reasonable grounds to believe that the breach may constitute an
imminent or obvious danger to the public interest.

b) Recipient

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The recipient of the external report is ANAC. The external report submitted to a subject otherthan ANAC is transmitted to the latter within seven days from the date of receipt, providing a
notice of its submission to the whistleblower at the same time.
c) Reporting channels and related implementation methods
The whistleblower can acquire information on implementation methods at www.anticorruzione.it
in order to submit an external report.
d) Subject of the report
Reports of violations of European Union provisions may be communicated through externalreporting.
e) Management of the report by ANAC
Following receipt of the report, ANAC carries out the following activities:•

gives notice to the whistleblower of receipt of the external report within seven days from thedate of its receipt, unless explicitly requested otherwise by the whistleblower or unless
ANAC believes that the notice would compromise confidentiality measures adopted toprotect the identity of the whistleblower;•holds discussions with the whistleblower and requests additional information from the latter,if necessary;•

duly follows up on the reports received;•

carries out the necessary investigations to follow up on the report, including hearings andacquisition of documents;•

replies to the whistleblower within three months or, in the presence of justified and wellfounded reasons, within six months from the date of notice of receipt of the external reportor, in the absence of such notice, from the expiration date of seven days from receipt;•

informs the whistleblower of the final outcome, which may also consist in archiving of thereport or its submission to the competent authorities (administrative, judicial, institutions andbodies of the European Union), or in a recommendation or administrative sanction.

6.3 Public disclosurea) Conditions for making a public disclosure
The whistleblower may make a public disclosure (relying on the protection provided by the
Whistleblowing Act) if, at the time of submission, one of the following conditions is met:12•

the whistleblower has previously made an internal and external report or has directly madean external report, in the manner provided for by articles 6.1 and 6.2, and no response has
been given within the terms provided therein regarding the measures envisaged or adopted
to follow up on the reports;•

the whistleblower has reasonable grounds to believe that the breach may constitute an
imminent or obvious danger to the public interest;•

the whistleblower has reasonable grounds to believe that the external report may involve therisk of retaliation or may not be effectively followed up due to the specific circumstances of
the case, such as those in which evidence may be concealed or destroyed or in which there
is a well-founded fear that the person who received the report may be in collusion with theperson responsible for the violation or involved in the violation itself.

b) Channels of public disclosure
The channels for making reports are the public press or electronic means, or in any casecommunication methods allowing to reach a large number of people.
c) Subject of the report
Reports of breaches of European Union provisions may be the subject of public disclosure.

7. FORMS OF PROTECTION FOR THE WHISTLEBLOWER
The whistleblowing system adopted by MISSONI ensures the confidentiality and protection of
personal data pertaining to the reporting party.
MISSONI also adopts all necessary measures to guarantee full protection of the whistleblower
against possible retaliatory, discriminatory or otherwise unfair conduct resulting from the report.
7.1

Confidentiality of the whistleblower's identity

Access to the internal reporting channel is allowed exclusively to the Channel Manager; if thewhistleblower uses his/her MISSONI email account, identified with the subject indicated inarticle 6.1 of this Procedure, for the purpose of sending the report, no one (including managers of
the IT systems) is authorised to view it.
Violation by any person of the provisions referred to in the previous paragraph is a source ofdisciplinary, contractual, and, where applicable, criminal liability.

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The identity of the whistleblower and any other information from which such identity may beinferred, directly or indirectly, may not be disclosed without the express consent of the same
whistleblower to persons other than the Channel Manager team, which is expressly authorised toprocess such data pursuant to Privacy legislation.
In the case of external reporting, the confidentiality of the identity of the whistleblower isguaranteed by ANAC.
In addition, to protect the whistleblower, it should be noted that:•in the context of criminal proceedings, the identity of the whistleblower is kept confidential
in the manner and within the limits provided for by article 329 of the Code of Criminal
Procedure "Obligation of secrecy";•as part of the procedure before the Court of Auditors, the identity of the whistleblower cannot
be revealed until the end of the investigation phase;•

within the framework of the disciplinary procedure, the identity of the whistleblower cannot
be revealed where a dispute on the disciplinary charge is based on separate and additional
findings with respect to the report, even if consequent to the same. If the dispute is based on
the report, in whole or in part, and the disclosure of the identity of the whistleblower isessential for the defence of the accused party, the report may be used for the purposes of thedisciplinary procedure only with the express consent of the whistleblower to disclose his/her
identity.

7.2

Prohibition of "retaliation"a) Prohibited acts of retaliation
MISSONI provides for absolute prohibition of any discriminatory measures against thewhistleblower; specifically, whistleblowing retaliation includes:-

dismissal, suspension or other equivalent measures;-

demotion or non-promotion;-a change of position or workplace, reduction in salary, change to working hours;-

the suspension of training activities or any restriction in access to training;-

negative assessment reports or references;-

the adoption of disciplinary measures or other sanctions, including financial penalties;-

coercion, intimidation, harassment or ostracism;-discrimination or any unfavourable treatment;

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-failure to convert a fixed-term employment contract into a permanent employment contract,
where the worker had legitimate expectations of such a contractual conversion;-

the non-renewal or early termination of a fixed-term employment contract;-

damage, including to the person's reputation, in particular on social media, or economic or
financial prejudice, including loss of economic opportunities and loss of income;-placing on erroneous lists based on a formal or informal sectoral or industrial agreement,
which may make it impossible for the person to find employment in the sector or industry in
the future;-

the early conclusion or cancellation of the contract for the supply of goods or services;-

the revocation of a licence or permit;-a request to complete a psychiatric or medical assessment.

Any retaliatory actions are null and void. Persons who have been dismissed due towhistleblowing (internal and/or external), public disclosure or reporting to the judicial or
accounting authority, are entitled to reinstatement in the workplace.
Any retaliation suffered can be communicated to ANAC, using the tools provided on the website
www.anticorruzione.it; in this case, ANAC informs the Italian National Labour Inspectorate
regarding the measures within its remit.
b) Conditions for the protection of the whistleblower
The protection against acts of retaliation referred to in the previous point applies in the presenceof the following conditions:•at the time of the report (internal and/or external), of the complaint to the judicial or
accounting authority or of the public disclosure, the whistleblower had reasonable grounds
to believe that the information included in the whistleblowing report, publicly disclosed orreported, was true and fell within the objective scope of application of this legislation;•

the report (internal and/or external) or public disclosure was made in compliance with thesteps provided for by article 6 of this Procedure.

Protection is also guaranteed in the event of reports or complaints made to the judicial or
accounting authority, or anonymous public disclosure, if the whistleblower has subsequently been
identified and suffered retaliation, as well as in cases of whistleblowing reports submitted to theinstitutions, bodies, offices and competent bodies of the European Union, in accordance with theprovisions of this legislation.

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Protection is not guaranteed and a disciplinary sanction is imposed on the whistleblower, when(i) the criminal liability of the whistleblower for the crimes of defamation or slander or, in any
case, for the same crimes committed with the complaint to the judicial or accounting authority,or (ii) his civil liability, for the same title, in cases of wilful misconduct or gross negligence isascertained, even with a first instance ruling.
c) Other subjects to whom the protection applies
The protection referred to in the previous letters also applies to the following subjects:•

any natural person who assists the whistleblower in the reporting process, operating within
the same work context, and whose assistance must be kept confidential (the so-called"facilitators");•

persons operating in the same work context as the whistleblower, as the person who has filed
a complaint with the judicial or accounting authority or as the person who has made a public
disclosure, and who are linked to them by a stable emotional or kinship bond within the
fourth degree;•

work colleagues of the whistleblower or of the person who has filed a complaint with thejudicial or accounting authority or made a public disclosure, who are operating in the same
work context and who have a current habitual relationship with said person;•

owned entities of the whistleblower, or of the person who has filed a complaint with thejudicial or accounting authority, or who has made a public disclosure, or entities where said
persons work, as well as entities operating in the same work context as the aforementioned
persons.

8. SANCTION SYSTEM
Violation of the provisions contained in the above paragraphs may trigger the sanctioning
procedure: in particular, the following are subject to sanction:(i)

a whistleblower who has made reports with intent or gross negligence or that prove to befalse, unfounded, with defamatory content or in any case made for the sole purpose ofdamaging the Company, the reported party or other persons affected by the report;(ii)

any person who has violated the confidentiality of the whistleblower;(iii)

a person responsible for acts of retaliation;(iv)

any person who has obstructed or attempted to obstruct the report.

For the relative sanctioning treatment, please refer to the provisions in chapter 7 of Model 231.

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The above behaviours can also be ascertained by ANAC, which imposes the following
administrative fines:-

for the conduct referred to in point (i), fines ranging from € 500.00 to € 2,500.00, unless thereporting person has been convicted in criminal proceedings, including in the first instance,
for the crimes of defamation or slander, or convicted for the same crimes through a complaint
to the judicial or accounting authority;-

for the conduct referred to in points (ii), (iii), (iv), fines ranging from € 10,000.00 to €50,000.00.

9.

RECORD KEEPING

Internal reports and all related documentation are retained for the time necessary to process thereport, and in any case no longer than five years from the date of communication of the final
outcome of the reporting procedure, in compliance with the confidentiality obligations referred
to in article 7.1 above.
For these purposes, the Channel Manager has established a computerised and paper archive,
insofar as may be necessary.
The storage of external reports is the responsibility of ANAC.
Any personal data contained in the report, including those related to the identity of thewhistleblower or other individuals, will be processed in compliance with the rules for protectionof personal data.

10.

AVAILABILITY OF THE PROCEDURE DOCUMENTATIONThis policy procedure documentation, in electronic or paper format, is available in the following
physical and electronic locations:•Website at https://www.missoni.com/it/ in the Corporate section;•

Company intranet at: https://hrportal.missoni.it/;•

Company bulletin board;•

At the entrance to all sites;•

HR Office.

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11.

UPDATING THE PROCEDURE

This procedure has been approved by the Board of Directors and is subject to periodic updating.

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