WHISTLEBLOWING

Calzaturificio Casadei S.p.a. upholds a commitment in its activities to operate according to ethical and governance principles that respect the highest standards. Therefore, as an essential requirement the Company demands ethical and professional integrity, correctness of behaviour and full compliance with laws and regulations, as well as with principles of honesty, reliability, impartiality, loyalty, transparency, fairness, and good faith in carrying out all activities.

Italian Legislative Decree no. 24 of 10 March 2023 on "the protection of persons who report violations of Union law and provisions on the protection of persons who report violations of national legislative provisions", governs the reporting procedures and the protections granted to whistleblowers.

In this context, Calzaturificio Casadei S.p.a. has implemented a whistleblowing system aimed at:

preventing, identifying and combating illegal activities;

protecting the company and shareholders from economic and reputational damage;

promoting a culture based on ethical and governance principles (e.g. ethics, legality, honesty, transparency);

The recipients of this policy are:

Employees of Calzaturificio Casadei S.p.a. and job applicants;

External collaborators;

Partner companies;

Suppliers;

any subject in contact with Calzaturificio Casadei S.p.a. for the purpose of their professional activity;

persons with administrative, managerial, supervisory, oversight or representative functions, even if such functions are exercised de facto within the company.

"Whistleblowing" (hereinafter also referred to as "report") means any report concerning potential violations, illegal or abnormal behaviour or conduct, including omissions, not compliant with national or European Union regulations that harm the public interest or the integrity of the COMPANY, Calzaturificio Casadei S.p.a., as well as the existing system of rules and procedures.

Calzaturificio Casadei S.p.a. has set up this external digital platform managed by an authorized third party in accordance with the GDPR. The platform ensures the effectiveness and confidentiality of the entire reporting process. The platform is accessible via the link:

https://casadei.onwhistleblowing.com

The platform ensures the protection of the Whistleblower, the person indicated in the report and any other individuals involved (e.g. "facilitators", family members, co-workers, etc.) in the report, in accordance with the applicable legislation, including European legislation.

Once the registration is completed by filling out the form with all the information, the platform will issue a numerical code - within 7 days - that will allow the progress of the handling of the report to be monitored. The whistleblower must receive a reply to the report within a maximum period of ninety days.

The recipient of reports is the Whistleblowing function, which reports to the human resources management function.

Anonymous reports

Reports that do not contain the whistleblower's identity are considered anonymous.

Anonymous reports are not processed; they will be recorded, however, only if they are adequately substantiated.

The protection measures provided to protect the whistleblower are also applicable should an initially anonymous whistleblower, who has reported having suffered retaliation due to their report, subsequently disclose his/her identity.

Even anonymous reports, and the related documentation, will be registered and stored for a period of five years from the date of receipt in order to be retrieved in cases where the whistleblower informs ANAC that they have suffered retaliation as a result of the report.

In the case of unfounded reports, made in bad faith or with serious negligence, Calzaturificio Casadei S.p.a. reserves the right to take action to defend its interests and protect the injured parties.

WHO IS THE WHISTLEBLOWER

A Whistleblower is the person who reports violations of national or European Union regulations that harm the public interest or the integrity of Calzaturificio Casadei S.p.a., which they have become aware of in the context of their work; specifically:

Employees of Calzaturificio Casadei S.p.a., including workers who perform occasional services.

Self-employed workers, including self-employment relationships specifically regulated under Article 2222 of the Italian Civil Code (works contract) (including freelancers and consultants who provide their services in Calzaturificio Casadei S.p.a.).

Holders of a collaboration relationship as referred to in Article 409 of the Italian Code of Civil Procedure, who carry out their work activity in Calzaturificio Casadei S.p.a., with the latter being understood as:

private work under an employment contract, even if not related to the exercise of a business;

agency relationships, commercial representation;

other forms of collaboration that result in the continuous and coordinated rendering of services, predominantly personal, even if not of a subordinate nature.

Volunteers and interns, paid and unpaid, who provide their services in Calzaturificio Casadei S.p.a.

Workers and collaborators, who provide goods or services or carry out works on behalf of Calzaturificio Casadei S.p.a.

Shareholders of Calzaturificio Casadei S.p.a.

Members of the board of directors and/or management or representation of Calzaturificio Casadei S.p.a., including members without executive positions (e.g. directors without or with powers of attorney), even when such functions are exercised de facto.

What can be reported

The subject of reports are violations that can be reported under the Whistleblowing Decree; i.e. those that the Whistleblower becomes aware of within their own work context that can harm the public interest or the integrity of Calzaturificio Casadei S.p.a. These violations consist of unlawful acts that fall within the scope of application of European Union or national legislation 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;

health and safety at work;

radiation protection and nuclear safety;

food and animal feed safety and animal health and welfare;

public health;

consumer protection;

protection of private life and personal data (to be understood as a violation of privacy regulations) and security of networks and information systems (Privacy Code, GDPR, and Legislative Decree 101/2018);

acts or omissions that harm the financial interests of the European Union;

acts or omissions concerning the internal market, including violations of EU competition and state aid rules, as well as violations concerning the internal market related to acts that violate corporate tax rules or mechanisms aimed at obtaining a tax advantage that undermines the purpose or objective of the applicable corporate tax legislation.

What CANNOT be reported

Under Legislative Decree no. 24 of 2023, disputes, claims or requests related to the personal interests of the Whistleblower or the person who filed a complaint with the Judicial Authority, which exclusively concern their individual employment relationships, cannot be subject to Reporting. This therefore excludes, for example, Reports concerning labour disputes and pre-litigation phases, discrimination among colleagues, personal conflicts between the reporting person and another worker or with hierarchical superiors, reports relating to data processing carried out in the context of the individual employment relationship in the absence of harm to public interest or the integrity of the private entity (ANAC Guidelines page 29).