Internal Reporting System for Violations (Whistleblowing) 
(Established pursuant to Legislative Decree No. 24/2023) 

Gellify Italia S.r.l. has complied with the requirements set forth in Legislative Decree No. 24 of 10 March 2023, which implements Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law, and introduces provisions for the protection of persons who report violations of national laws (commonly known as “Whistleblowing”).

This Decree regulates the protection of individuals who report breaches of national or EU regulations that harm the public interest or the integrity of public administration or private entities, which they become aware of in the context of their work. 
According to the Decree, the violations that can be reported (when known in the context of a working relationship with the Company) include:

• Unlawful conduct relevant under Legislative Decree No. 231/2001 or violations of the Organization, Management and Control Model adopted by the Company (“Model 231”), not included under the categories below;
• Breaches in the fields of: public procurement; financial services, products and markets and the prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety, animal health and welfare; public health; consumer protection; privacy and personal data protection; and the security of networks and information systems;
• Acts or omissions harming the EU’s financial interests;
• Acts or omissions affecting the internal market, including violations of competition and state aid rules, and breaches aimed at obtaining a tax advantage for the Company.

In line with the Decree, personal grievances, complaints, or requests that are solely linked to the individual working relationship or collaboration and are of a personal nature, may not be submitted via the whistleblowing system. 
Who can report violations: 

• Employees;
• Self-employed workers and individuals with a collaboration agreement;
• Workers or collaborators supplying goods or services or executing works in favor of third parties (suppliers);
• Freelancers and consultants;
• Volunteers and interns;
• Shareholders and individuals in administrative, managerial, supervisory, monitoring, or representative roles (including those exercising such functions de facto).

The protection measures under the Decree also apply to facilitators; individuals in the same working context as the whistleblower; co-workers with a regular and ongoing relationship with the whistleblower; and entities owned by the whistleblower or operating in the same working context.

How to report a violation:

Reports can be submitted in written or oral form via the online platform at: https://gellify.wallbreakers.it 
The Company has appointed the Chair of the Supervisory Body, Mr. Stefano Logroscino (Lawyer), a professional with significant expertise in whistleblowing matters, to manage the reporting channel, as provided for by Article 4, paragraph 2 of Legislative Decree No. 24/2023.

Oral reports may also be submitted following a specific request for a meeting with the external office responsible for managing reports. Internal report handling includes:

1. Acknowledgement of receipt within seven days from submission;
2. Ongoing communication with the whistleblower, who may be asked to provide additional details;
3. Diligent follow-up on received reports;
4. A response within three months from the date of acknowledgement of receipt or, if none, within three months from the expiry of the seven-day acknowledgment deadline.

Reports must include a detailed description of the facts, events, or circumstances that may constitute the alleged violation, with enough information to at least hypothetically identify key elements for verifying the credibility of the report.

In accordance with Legislative Decree No. 24/2023, the Company ensures the whistleblower’s confidentiality and prohibits any form of retaliation or discrimination against them. The identity of the whistleblower and any other information from which their identity can be directly or indirectly inferred will not be disclosed without their explicit consent, except to persons authorized to receive or follow up on the reports, as permitted under personal data protection legislation.

All personal data and information provided through the reporting system are processed for the purpose of managing and investigating the reports and taking any necessary actions, in compliance with applicable laws, including data protection regulations. Full details on data processing purposes and methods can be found in the Privacy Notice pursuant to Article 13 of Regulation (EU) 2016/679, available in the attachments section of this page.

Violating the duty of confidentiality constitutes a disciplinary offense, without prejudice to any further legal responsibilities. 
Please note: if a report proves to be unfounded and was made with willful misconduct or gross negligence by an employee, disciplinary measures may be considered.

For further information on how to file a report and the Company’s procedure for handling reports, please refer to the document “Procedure for the Management of Whistleblowing Reports”. For additional legal references, please consult Legislative Decree No. 24/2023.

Attachments:

Download the Procedure for the Management of Whistleblowing Reports (Italian)
Download Whistleblowing Privacy Notice (Italian)

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