DENONCE

According to the Directive (EU) 2019/1937, the Legislative Decree No. 24 of 10 March 2023 has regulated the protection of persons who report breaches of national or European regulations - which they have become aware of in a public or private work context - that may harm the public interest or the integrity of companies (such as administrative, accounting, civil or criminal offences and unlawful conduct relevant under Legislative Decree No. 231/2001, etc.), replacing the existing national whistleblowing regulations.

This legislation has extended the existing rules also to companies which do not have Models pursuant to Legislative Decree no. 231/2001.

IMA Italia Assistance S.p.A and IMA Servizi S.c.a.r.l. had already ensured the provisions of the previous legislation on whistleblowing, by setting up:

• adequate information channels enabling whistleblowers to submit, for the protection of the entity's integrity, circumstantiated reports of unlawful conduct, relevant under the law and based on precise and concordant factual elements:

- by mail, addressed to the Organismo di Vigilanza at the offices of IMA Italia Assistance S.p.A. and IMA Servizi S.c.a.r.l. - Piazza Indro Montanelli 20 - Sesto San Giovanni (20099-Milan);

- by e-mail to the Organismo di Vigilanza of IMA Italia Assistance at odvimaitalia@imaitalia.it and to the Organismo di Vigilanza of IMA Servizi odvimaservizi@imaitalia.it ;

• an alternative reporting channel capable of ensuring, by computerized means, the confidentiality of the reporter's identity, which can be reached at https://whistleblowing.imaitalia.it;

• measures to ensure the protection of the reporter from retaliatory or discriminatory acts against the reporter for reasons directly or indirectly related to the report and, more generally, a timely and non-abusive use of the new reporting tool.

In line with the new legislation, IMA Italia Assistance S.p.A and IMA Servizi S.c.a.r.l. have further expanded the reporting channels by introducing the possibility of reporting to ANAC - the National Anti-Corruption Authority - and Public Disclosure in the cases provided for by the law. The reporting parties, the types of conduct reported, the time at which it is possible to report, the provisions on confidentiality and privacy, the protective measures provided for violations of the confidentiality of the reporter and the prohibition of retaliation against the reporter have also been brought into line with the new legislation.

The Whistleblowing Procedure of the companies can be consulted below.

The Chairmen of the Organismo di Vigilanza of IMA Italia Assistance S.p.A and IMA Servizi S.c.a.r.l.