Report securely and confidentially

Sardinia Solar Energy 2 (SSE2) promotes a corporate culture based on integrity, responsibility, transparency and compliance with the rules.

In accordance with Italian Legislative Decree No. 24 of 10 March 2023, SSE2 provides a dedicated internal reporting channel through which conduct, acts or omissions that may constitute breaches of national or European Union legislation and may harm the public interest or the integrity of the company can be reported securely and confidentially.

Reports must be made in good faith and on the basis of information believed to be true at the time of reporting.

SUBMIT A REPORT

What is Whistleblowing?

Whistleblowing is a tool that allows anyone who becomes aware of possible wrongdoing or irregularities in the course of their work or professional activities to report them through protected channels.

The system is designed to facilitate the timely identification of conduct that does not comply with the law, company procedures or the principles of fairness and integrity, while ensuring the confidentiality of the reporting person and protection against any retaliatory conduct.

Who can submit a report?

The channel is available to anyone who has acquired information about possible breaches within their work-related or professional context, including:

• employees and collaborators;
• self-employed workers and consultants;
• independent professionals;
• volunteers and trainees, whether paid or unpaid;
• shareholders and persons performing administrative, management, supervisory, oversight or representative functions;
• employees and collaborators of suppliers, contractors, subcontractors and business partners;
• candidates and persons involved in recruitment processes or other pre-contractual stages;
• former employees and persons whose relationship with the company has ended, where the information was acquired during that relationship.

Where provided for by law, the protections established by the applicable legislation may also extend to facilitators and to persons connected to the reporting person through personal or professional relationships.

What can be reported?

Reports may concern conduct, acts or omissions of which the reporting person became aware within a work-related context and which may constitute a breach.

By way of example, reports may concern:

• breaches of national or European Union legislation;
• fraud, corruption or other unlawful conduct;
• breaches relating to public procurement, the environment, health and safety;
• breaches concerning financial services, products and markets;
• conduct that may compromise the safety of operations or facilities;
• breaches of company procedures and internal control systems;
• conduct intended to conceal a breach or prevent it from being identified;
• acts or conduct that may harm the public interest or the integrity of the company.

Reports should be as detailed as possible and contain sufficient information to enable the reported facts to be verified.

Where available, it is useful to provide:

• a clear description of the facts;
• the place and period in which they occurred;
• the persons involved;
• any persons who may have knowledge of the facts;
• documents, communications or other information that may assist with the assessment.

It is not necessary to possess conclusive evidence. However, the reporting person must have reasonable grounds to believe that the information reported is true at the time the report is submitted.

What should not be reported through this channel?

The Whistleblowing channel must not be used for:

• complaints, claims or requests relating exclusively to a personal interest;
• individual employment disputes that are not connected to breaches falling within the scope of Whistleblowing legislation;
• commercial complaints or ordinary support requests;
• reports based exclusively on rumours or information unsupported by specific facts;
• allegations that are knowingly false or made intentionally or with gross negligence.

General or commercial enquiries may be submitted through Futura Group’s standard contact channels.

Confidentiality and protection of identity

The identity of the reporting person will not be disclosed to anyone other than those authorised to receive and manage the report, except in the cases expressly provided for by law.

This protection applies not only to the reporting person’s name, but also to any information from which their identity may be directly or indirectly inferred.

The same care is applied to the identity of the persons concerned and any other persons mentioned in the report.

All information is processed in accordance with the principles of necessity, proportionality and confidentiality.

Anonymous reports

A report may be submitted without disclosing the reporting person’s identity, where permitted by the platform and the applicable procedure.

Anonymous reports may be considered where they are sufficiently detailed and contain specific information enabling an assessment to be initiated.

However, an identified report may facilitate the investigation and allow the person responsible for managing the report to request clarifications or additional information.

In all cases, it is important to retain the identification code issued by the platform in order to monitor the progress of the report and communicate confidentially with the person responsible for managing it.

How the report is managed

Reports are managed by an independent person or body that has been specifically appointed and authorised.

Upon receiving a report, the person responsible for its management:

1. issues an acknowledgement of receipt within 7 days;
2. carries out a preliminary assessment of the report;
3. maintains communication with the reporting person where necessary;
4. may request clarifications or additional information;
5. carries out any investigations and checks considered necessary;
6. provides feedback within the time limits established by law.

Feedback is normally provided within 3 months from the date of the acknowledgement of receipt or, where no acknowledgement has been issued, from the expiry of the 7-day period following submission of the report.

The feedback may concern:

• the closure of the report without further action;
• the checks carried out;
• the commencement of a further investigation;
• the adoption or proposed adoption of subsequent measures;
• the referral of the report to the competent authority.

The right to receive feedback does not necessarily entail the disclosure of every detail of the investigation, particularly where this could compromise the rights of third parties, confidentiality obligations or further investigative activities.

Protection against retaliation

Anyone who submits a report in accordance with the conditions established by law is protected against any form of retaliation directly or indirectly connected with the report.