Internal Alert Procedure of the Sella group companies (Whistleblowing)

The "Internal Alert Procedure" (also called "whistleblowing") is one tool for preventing and correcting acts or facts that may constitute foreseen illicit conduct from external and internal regulations (such as the Code of Conduct or the Corporate Governance Code), which are harmful of the public interest or the integrity of the private entity, encouraging and protecting the positive behavior of personnel or other legitimate subjects identified by the legislation, who, having become aware of the illegality or the illegitimacy of the actions of another person in the workplace, decide to report confidentially such acts or facts to the relevant bodies.

An effective whistleblowing system represents an important tool for the Sella group for constantly respecting the canons of transparency and integrity in its actions and a useful alarm bell that allows the appropriate measures to be adopted.

Reports can be forwarded to the internal alert procedure by employees and by those who in any case operate on the basis of relationships that determine their inclusion or a relationship with the company organisation, even in a form other than an employment relationship, such as:

• self-employed workers, external workers and collaborators, freelancers and consultants who carry out their work at the Group;
• paid and unpaid volunteers and interns;
• shareholders and people with administrative, management, control, supervisory or representative functions;
• personnel of suppliers external to the Group.

The reports may concern any act or fact that may constitute a violation of the external rules governing the activity carried out (banking activities pursuant to the TUB and the provision of investment services pursuant to the TUF as well as those of distribution of insurance products), and of internal Group regulations. The reports may also concern the offenses provided for by Legislative Decree 24/2023 (such as for example environmental protection, public procurement, protection of private life, protection of personal data, security of networks and information systems etc.), violations, potential or actual, of the provisions dictated for the prevention of money laundering and terrorist financing as provided for by the art. 48 of Legislative Decree 231/2007, any other illicit conduct pursuant to Legislative Decree 231/01 as well as any violation of the organizational model adopted by the Company. The report may also concern any act or fact that may constitute a violation of antitrust legislation (Law 10 October 1990, n. 287 - Rules for the protection of competition and the market).

Sella Group protects the whistleblower "against retaliatory, discriminatory, or otherwise unfair behavior following the report", respecting the dignity of the whistleblower.

Reports can be forwarded in written or oral form or through a direct meeting through the dedicated IT procedure accessible via the following link:
https://www.mygovernance.it/whistleblowing-gruppo-sella/

Furthermore, the whistleblower can use the external communication channel, established by ANAC, when one of the following conditions occurs:

• The internal channel has been previously used, but there has been no response or follow-up;
• There is an "imminent danger to the public interest";
• The internal channels have not been used due to the risk of retaliation or the ineffectiveness of those systems.