Whistleblowing

Reports of Alleged Irregularities

What is “Whistleblowing”?
The term whistleblowing refers to the reporting, by an individual known as a “whistleblower”, of unlawful conduct or irregularities committed within a company with which they have a qualified relationship or perform any type of activity (as a director, employee, contractor, intern, or volunteer), of which they have direct knowledge or reasonable suspicion, and which is considered harmful to the public interest or to the integrity of the company.

At HS Marine S.r.l., regardless of the legal meaning of the term “whistleblowing” in local legislation, a “report of alleged irregularity” refers to any instance in which a person (employee or non-employee) communicates, discloses, or reports any behavior, information, transaction, or activity that is presumed or alleged to be inappropriate, improper, unethical, or unlawful (even if only potentially or apparently so).

Why is it important to report?

HS Marine S.r.l. reaffirms its commitment to acting with the highest standards of honesty and integrity.
This commitment is essential not only to ensure strict compliance with laws and regulations but also to gain and maintain the trust of our customers, employees, and business partners.

In this context, HS Marine S.r.l. is committed to protecting those who report violations, recognizing that such reports provide a valuable and essential contribution to the achievement of these objectives.
In particular, HS Marine S.r.l. encourages the prompt reporting of any actions, omissions, or practices believed to be inappropriate or non-compliant with applicable laws and regulations.

What can be reported through the Whistleblowing system?

Under European and national legislation, reports may concern:

• Actual or potential violations, of which one has knowledge or reasonable suspicion;
• Conduct presumed to be inappropriate, improper, unethical, or unlawful (even if only potentially or apparently so);
• Any criminal offense, including attempted crimes, or administrative violations;
• Concealment or attempted concealment of such violations, conduct, or offenses, occurring or potentially occurring within HS Marine S.r.l.

By way of example, alleged irregularities may relate to:

• Actions, behavior, or omissions that harm the public interest or the integrity of a public administration or private entity;
• Administrative, accounting, civil, or criminal offenses;
• Unlawful conduct under Legislative Decree 231/2001 or violations of the organizational and management models provided for therein;
• Violations of EU law or national laws connected to the Directive;
• Corruption, extortion, embezzlement, fraud, money laundering, deceit against the State or the EU, environmental crimes, cybercrime, tax offenses, or breaches of workplace safety regulations.

In addition to the examples listed above, other areas of relevance may be covered as defined under Legislative Decree 24/2023, where applicable to the company’s activities.

How can a report be submitted?

HS Marine S.r.l. encourages the prompt reporting of any practices or actions believed to be inappropriate or non-compliant.
To this end, HS Marine S.r.l. provides a communication channel through which reports may be submitted—either nominally or anonymously—at the following link:
 https://whistleblowing.dataservices.it/HSMARINE

In addition to the internal reporting channel mentioned above, reports may also be submitted externally to the National Anti-Corruption Authority (ANAC) or through public disclosure.
These external methods are available only as a last resort, in the cases defined by law and detailed in the ANAC Guidelines, available at:
 https://www.anticorruzione.it/-/whistleblowing

Reporting management timelines

• Acknowledgment of receipt of the report shall be provided to the reporting person within seven (7) days from receipt.
• Follow-up or feedback on the outcome of the investigation, or—if still ongoing—an update on its progress, shall be provided within three (3) months from the acknowledgment of receipt, or, if no acknowledgment was issued, within three months from the expiry of the seven-day acknowledgment period.

How is the Whistleblower protected?

The law requires the confidentiality of all individuals involved in the reporting process.
Protection extends not only to the whistleblower but also to facilitators, colleagues, and family members.

The whistleblower, provided they acted in good faith, is protected by law and internal procedures that ensure the highest level of confidentiality and protection—even if the reported facts are later found to be unfounded or inaccurate.

This means a guarantee of:

• Confidentiality: The identity of the reporting person, as well as any information from which such identity could be inferred, cannot be disclosed without the individual’s explicit consent, except in cases expressly provided by law, and only to authorized persons responsible for handling the reports.
• Protection from retaliation: Such as disciplinary sanctions, discriminatory measures, or any other actions causing harm or adverse consequences related to the report.

The same confidentiality and protection apply to persons mentioned in the report or otherwise involved in it.

However, in cases where reports are made in bad faith, HS Marine S.r.l. reserves the right to protect its interests and the rights of affected individuals.
It may impose disciplinary measures or report to the competent authorities any individuals who make bad-faith or malicious reports intended solely to harm the company, the reported person, or others involved.
The same measures apply to anyone found to have violated whistleblower protection obligations.

The reporting system allows individuals to quickly and easily report concerns regarding actual or suspected misconduct that may negatively impact the company or the well-being of its people.

The reporting system must not be used to make false accusations against others, nor to submit deliberately inaccurate information.
All reports are treated with strict confidentiality.