Whistleblowing Notice for the Website

Caffè Borbone, in accordance with Legislative Decree No. 24/2023 (the so-called “Whistleblowing Decree”) and in full compliance with applicable laws, has adopted a whistleblowing reporting management process aimed at helping prevent unlawful acts, irregularities or misconduct occurring within Caffè Borbone’s working environment.

As required by applicable legislation, Caffè Borbone guarantees the protection of the identity of the reporting person and of the persons involved and/or mentioned in the report, as well as the confidentiality of the content of the report. The Company also undertakes to implement all forms of protection provided for against retaliatory and/or discriminatory conduct.

The content of the report, as well as any information relating to the identity of the reporting person, will be disclosed only to the persons competent to receive or follow up on the reports. Without the express consent of the reporting person, no other party may have access to such information.

Who may submit a report?

Pursuant to Article 3 of the Decree, the persons who may submit reports include:

• 
  employees, including during the probationary period, self-employed workers, as well as collaborators, freelancers and consultants who carry out their work for the Company;
  
• 
  shareholders and persons with administrative, management, control, supervisory or representative functions;
  
• 
  trainees carrying out their activities for the Company;
  
• 
  employees or collaborators of contractors, subcontractors and suppliers of the Company;
  
• 
  former employees of the Company;
  
• 
  candidates for a job position at the Company who have obtained information on violations during the recruitment process or in other stages of the pre-contractual negotiations.
  

In short, this includes any person who, in any capacity, comes into contact with the Company.

What can be reported?

Reports may concern acts, conduct or omissions committed or which, on the basis of concrete elements, could be committed within Caffè Borbone’s working environment in breach of national or European Union legislation referred to in Article 2 of the Decree, as well as violations of the Code of Ethics, the Organisational and Management Model pursuant to Legislative Decree No. 231/2001, employment contracts and internal company regulations (rules, policies, procedures, operating instructions, etc.).

For the sake of clarity, this also includes reports of violations of antitrust law, meaning the set of European and national rules designed to protect competition between companies.

The report must be complete, detailed and substantiated. The reporting person is therefore required to provide all available and useful elements to allow appropriate verification and assessment of the validity of the reported facts.

Internal reporting channels

To submit a report, Caffè Borbone has made the following channels available:

• 
  online platform, accessible at:
  
  https://caffeborbone.integrityline.com
  
• 
  ordinary mail, to the address:
  
  Caffè Borbone S.r.l. – Zona ASI Loc. Pascarola 80023 Caivano, Naples, Italy – for the attention of the Supervisory Body (Organismo di Vigilanza);
  
• 
  direct meeting with the Supervisory Body.
  

Please note that the online platform allows reports to be submitted both in written and oral form and also enables anonymity.

The Supervisory Body receives and manages the reports and keeps the reporting person informed of the progress of the case within the following timeframes:

• 
  within 7 (seven) days of receipt of the report, an acknowledgment of receipt is issued;
  
• 
  within 3 (three) months from the date of the acknowledgment of receipt, or, if no acknowledgment is sent, within 3 (three) months from the expiry of the seven-day period from submission of the report, feedback is provided on the follow-up given or intended to be given to the report.
  

External reporting channel

In the exceptional cases provided for by law (see Article 6 of Legislative Decree No. 24/2023), the reporting person — under their own responsibility — may submit the report to the National Anti-Corruption Authority (ANAC) through the channels made available by that Authority.

How are personal data processed?

Within the whistleblowing reporting management process, personal data are processed in compliance with applicable data protection legislation (EU Regulation 679/2016 – GDPR and Legislative Decree No. 196/2003, as amended by Legislative Decree No. 101/2018).

For further details, please refer to the privacy notice on the processing of personal data of the reporting person and of the reported person.

The above notice, provided in accordance with applicable law, constitutes an extract from the Company’s “Whistleblowing Reporting Management Procedure.”