Whistleblowing Policy

1. Subject and Purpose

   This policy (hereinafter referred to as the “Whistleblowing Policy” or “Policy”) concerns the protection of individuals who report violations of (a) national or European Union regulations that undermine the public interest or the integrity of LongLife; or (b) our Code of Ethics.

2. Applicability

   This Policy applies to the following individuals (collectively, the “Whistleblowers”):

   • LongLife employees;
   • Self-employed workers and/or collaborators – including those under article 409 of the Italian Code of Civil Procedure – of LongLife;
   • Freelancers and consultants of LongLife;
   • Volunteers and interns of LongLife;
   • Shareholders, individuals exercising administrative, managerial, supervisory, oversight, and representation functions for LongLife;
   • Any person working under the supervision and direction of contractors, subcontractors, and suppliers of LongLife.

   A comprehensive list of Whistleblowers protected by this Policy is outlined in Article 3, Paragraph 2, of Legislative Decree No. 24 of March 10, 2023 (hereinafter, the “Whistleblowing Decree”) available at the following link: https://www.gazzettaufficiale.it/eli/id/2023/03/15/23G00032/sg.

3. Types of Violations to be Reported

   This Policy applies to conduct of which the Whistleblower becomes aware in the work context and which constitutes:

   • one of the relevant violations under the Whistleblowing Decree, as listed in Appendix 1 to this Policy; or
   • a violation of our Code of Ethics (hereinafter collectively referred to as the “Violations”).

   For illustrative purposes, some examples of key Violations to be reported under this Policy include:

   • Corruption
   • Fraud
   • Theft
   • Health and safety risks
   • Sexual harassment
   • Conflict of interest
   • Environmental risk or harm.

4. False Reports - Excluded Cases

   This Policy should not be used to make reports (a) known to be untrue or (b) in the absence of a reasonable suspicion that a Violation has occurred or may occur. Such reports are not protected under the Whistleblowing Decree and may result in consequences under applicable law.

   To be clear, it is appropriate to make reports if, based on reasonable and concrete evidence, there is a reasonable suspicion of a Violation. In this case, even if the Violations are not substantiated, the Whistleblower will not face any repercussions and will be protected in accordance with the Whistleblowing Decree.

   Notwithstanding the above, this Policy should not be used:

   • if someone's life is in danger: in this case, emergency services should be contacted;
   • to raise personal disputes or requests regarding one's employment contract or relationship with superiors: in this case, individuals can directly approach the People & OD Manager or follow the various channels provided by applicable law;
   • for product-related issues (for example, reporting a different color from before or difficulty opening a package): in this case, individuals can contact the switchboard, which will connect them with the relevant contact person.

5. Whistleblowing Committee

   To ensure the best application of this Policy and the protection of Whistleblowers in accordance with the Whistleblowing Decree, LongLife has established a dedicated committee responsible for managing reports of Violations governed by this Policy (hereinafter, the “Whistleblowing Committee”).

   As of the date of this Policy, the Whistleblowing Committee is composed of the managing directors Giuseppe Galliani, Roberta Bucin, and Leone Galliani, as well as the People & OD Manager, Roberta Marenco (hereinafter, the “Members of the Whistleblowing Committee”).

   Any changes to the Whistleblowing Committee and its members will be communicated in advance.

6. Internal Reporting Procedure

   LongLife has activated an internal reporting channel for relevant Violations under the Whistleblowing Decree, aimed at ensuring the confidentiality of the Whistleblower's identity, the individuals involved, and any individuals mentioned in the report, as well as the content of the report and related documentation.

   The internal reporting channel can be activated by the Whistleblower through various methods:

   • Anonymous Internal Reporting Channel

     An online reporting channel can be used by clicking on the link https://longlife.integrityline.com. Through this channel, reports can be made anonymously (or, if anonymity is not deemed necessary by the Whistleblower, by providing personal information). This channel will be managed by the People & OD Manager, with the support of the People Specialist, Vanessa Marino.

   • Other Internal Reporting Channels

     1. Reports can be sent via email to the dedicated email address managed by the People & OD Manager: whistleblowing@longlife.com;

     2. Individuals can also call the switchboard (02/5165531) and request to speak with one of the Members of the Whistleblowing Committee. If this channel is used, please note:

        • it will be necessary, as the first step, to specify that a Whistleblowing report is being made;
        • the switchboard (once informed that it is a whistleblowing report) - to protect the whistleblower's confidentiality - will not ask for identity information but will connect the whistleblower with an available Member of the Whistleblowing Committee.

   • Internal Reporting Channel Reserved for LongLife Employees

     In addition to the channels mentioned above, each LongLife employee can directly approach one of the Members of the Whistleblowing Committee in person.

7. Management of Reports

   In accordance with the Whistleblowing Decree, it is informed that following the report of a Violation, the Whistleblower will receive:

   • normally within 7 days from the date of receipt of the report, an acknowledgment of receipt of the report;
   • within 3 months from the date of the acknowledgment of receipt or from the expiration of the deadline for sending it, a response regarding the outcome of the investigations carried out following the report.

   Reports are received and managed by one or more Members of the Whistleblowing Committee who will take all necessary actions to verify their validity.

   For further investigations following the report, other employees and collaborators or external individuals may be involved, however still maintaining a limited number of individuals involved (only those strictly necessary). Every individual involved in the investigations is obliged to maintain total confidentiality and not share or discuss any information with anyone else. Violations of confidentiality and secrecy obligations may result in disciplinary action, subject to further responsibilities under the law.

8. Anonymity

   In some situations, it is understandable that the Whistleblower may need to remain anonymous, but considering that anonymous reports are more difficult to investigate, it is strongly recommended to make non-anonymous reports.

   It is clarified that even non-anonymous reports will be handled in a manner that ensures the confidentiality of the Whistleblower's identity, the individuals involved, and any individuals mentioned in the report, as well as the content of the report and related documentation.

   It is reiterated that no form of retaliation will be tolerated within the company against those who in good faith report a suspicion of Violations.

9. Information to Provide in the Report

   It is very helpful to provide as much detail as possible to facilitate further investigation.

   In particular, it is important that the following information are clear:

   1. the time and place circumstances in which the reported incident occurred;
   2. a description of the incident;
   3. details or other elements that allow the identification of the subject to whom the reported facts should be attributed.

10. Subsequent Procedure after the Report

    If the report is found to be valid, appropriate measures will be taken, including, but not limited to, disciplinary measures, new internal processes and policies, and reporting to competent authorities where necessary.

11. Confidentiality Protection

    Investigations will be conducted carefully to protect the confidentiality of all parties involved (whistleblower, any reported individual, any other individuals involved). The identity of the whistleblower, unless explicitly authorized in writing, will not be disclosed outside of designated individuals responsible for receiving or following up on reports, except in situations where there are legal obligations to disclose information externally.

12. Data protection

    Data processing will be carried out in compliance with current personal data protection regulations. Reports and related documentation will be retained for no more than five years from the date of communication of the outcome of the reporting procedure, in compliance with the confidentiality obligations under Article 12 of the Whistleblowing Decree and the principle outlined in Article 5, paragraph 1, letter e), of the GDPR.

13. External Reporting Channel

    The National Anti-Corruption Authority (hereinafter “ANAC”) has activated an external reporting channel.

    This external reporting channel should only be activated in the following cases:

    • there is no internal reporting channel or it does not comply with the Whistleblowing Decree;
    • internal reporting, made in accordance with this Policy, has not been followed up;
    • the whistleblower has reasonable grounds to believe that, if they were to make an internal report, it would not be effectively followed up or that the same report may result in the risk of retaliation;
    • the whistleblower has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest.

    Upon the occurrence of the aforementioned conditions, the external reporting channel can be activated by the whistleblower by accessing the address https://www.anticorruzione.it/-/whistleblowing and clicking on the “access the service” button.

14. Additional Information and Clarifications

    In case of doubts, further information can be requested from the People & OD Manager.

    A copy of this Policy is available in the dedicated section of the company's website.

ATTACHMENTS

Appendix 1 - Relevant Violations under the Whistleblowing Decree

Behaviors, acts, or omissions that harm the public interest or the integrity of LongLife and consist of:

1. Unlawful conduct relevant under Legislative Decree No. 231 of June 8, 2001, or violations of the organizational and management models provided therein, which do not fall under numbers 2), 3), 4), and 5);
2. Offenses falling within the scope of application of European Union or national acts indicated in the annex to the Whistleblowing Decree or national acts implementing the acts of the European Union indicated in the annex to Directive (EU) 2019/1937, even if not listed in the annex to the Whistleblowing Decree, relating to the following sectors: public procurement; services, financial products and markets, and prevention of money laundering and terrorism financing; product safety and compliance; transportation safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; protection of privacy and personal data and security of networks and information systems;
3. Acts or omissions harming the financial interests of the Union referred to in Article 325 of the Treaty on the Functioning of the European Union specified in the relevant derived law of the European Union;
4. Acts or omissions concerning the internal market, as referred to in Article 26, paragraph 2, of the Treaty on the Functioning of the European Union, including violations of European Union competition rules and state aid, as well as violations concerning the internal market related to acts violating corporate tax rules or mechanisms aimed at obtaining a tax advantage that frustrates the purpose or objective of the applicable corporate tax legislation;
5. Acts or behaviors frustrating the purpose or objective of the provisions of the Union acts in the sectors indicated in numbers 2), 3), and 4).