Whistleblowing Policy

What is the Whistleblowing Policy?

This policy sets out the framework by which individuals can report, in conditions of confidentiality or anonymity, breaches of the law, internal rules or ethical standards within MARYMANTES SPEED SRL. The policy is aligned with Law no. 361/2022, which transposes Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law.

The policy applies to all employees, former and future employees, temporary workers, contractors, suppliers, business partners, persons working under the supervision of contractors or suppliers, third parties and legal entities connected to the reporting person.

Why do we use the reporting mechanism?

The company encourages the early reporting of irregularities to protect the integrity, safety, compliance and reputation of the organisation, and to ensure the prompt remediation of non-compliant situations.

The objectives are: to encourage good-faith reporting, to establish a clear process for submitting and managing reports, to protect reporting persons against retaliation and to ensure confidentiality.

What situations can be reported?

Bribery, corruption, conflict of interest, anti-competitive practices, harassment and discrimination
Accounting, auditing or public reporting issues
Violations of human rights or competition law
Conduct that damages the company’s reputation
Breaches of health and safety at work
Environmental damage
Money laundering or breach of sanctions
Non-compliance with product safety and conformity
Privacy, data protection or IT systems and network security violations
Consumer protection law breaches
Any other criminal activity or breach of legal obligations

Customer complaints about the quality of services or products are managed by the relevant departments and are not covered by this policy.

Reporting channels

Reports can be submitted confidentially or anonymously through the following internal channels:

Web platform: https://marymantesgroup.whistleblowup.com
Email: conformitate@marymantesgroup.com
In person, verbally or in writing, to a member of the Designated Team: HR Director, Legal Manager, Internal Audit Manager

If a verbal report is made to a designated person, a written record will be prepared on a durable medium with the reporter’s consent. Without consent for transcription/recording, the report must be submitted in writing, electronically, to the above-mentioned email address.

Minimum content of a report

Name, contact details and professional context in which the information was obtained (if not anonymous)
Name of the person(s) concerned, if known
Detailed description and documentation of the facts, sequence of events and how they became known
Date, place and people involved, as well as witnesses or others who may provide further information
Supporting documents or references that can verify the facts

Reports may also be submitted anonymously in writing, electronically, to the dedicated email address.

Managing reports and deadlines

Acknowledgement of receipt will be sent within 7 days. Feedback on the status of resolution will be communicated within 3 months from the acknowledgement or, if no acknowledgement was sent, within 3 months after the 7-day deadline following submission. If the necessary measures are still being determined, this will be communicated to the reporting person.

Exception: feedback may be delayed if informing the reporter could jeopardise the resolution process.

Confidentiality and anonymity

Only the Designated Team has access to reports. The identity of the reporting person and any identifying information will remain confidential throughout the process, within the limits of the law. A unique report identification code may be allocated to allow follow-up communication and status updates.

No retaliation

Any form of retaliation against those who report in good faith or cooperate in investigations is strictly prohibited. Breaches of this prohibition will result in disciplinary measures, which may lead to termination of employment. Protection also extends to family members and entities linked to the reporting person.

Good faith and responsibility in reporting

The reporting person must have reasonable grounds to believe that the information is true and falls under this policy. Reports made in bad faith or containing deliberately false information will be treated as a serious offence and may result in disciplinary or legal consequences.

Investigation

All reports will be investigated promptly, objectively and with confidentiality. Where employees are involved, the HR Department will participate in the investigation. At the end, a summary report with conclusions and an action plan will be prepared and shared with the management of relevant departments.

Closing internal reports

The report does not contain the minimum required information, a 15-day completion request was made and not fulfilled
An anonymous report does not contain sufficient information for review, a 15-day completion request was made and not fulfilled
Multiple reports on the same matter are consolidated; without additional relevant information, subsequent reports are closed
The designated person may close the procedure in cases of clearly minor breaches, respecting confidentiality and informing obligations

Record keeping

All information related to a report will be kept for 5 years from the date of the solution communication, in a register maintained in accordance with the law, with appropriate IT security and access control measures. After this period, the data will be destroyed regardless of medium.

Step-by-step reporting

Assess if the issue can be resolved with your direct manager or HR; otherwise use the reporting channels
Select the channel: web platform, email or in person
Include the minimum required information for verification
Keep the identification code (if assigned) for follow-up communication
Receive acknowledgement within 7 days and feedback within 3 months

Revisions and entry into force

The policy is approved by the General Director and published on the website, on internal communication channels and displayed at company headquarters in a visible and accessible place. Any revisions will be communicated in the same way.

Effective date: 01.09.2025.