Adopted on 15 July 2023

Rev. 1 of 14 July 2026 - gender equality additions

In order to contribute to preventing offences, conduct in violation of the Organisation, Management and Control Model pursuant to Legislative Decree no. 231/2001 ('Model 231'), the Code of Ethics and, in general, violations or internal irregularities of the corporate procedures adopted, as well as of national or European laws or regulations, PhotoSì ('Company') has adopted a Reporting System, aimed at allowing personnel to report acts or facts that may constitute a violation of the aforementioned rules.

The Reporting System and management process are implemented in accordance with Legislative Decree no. 24/2023, known as the 'Law on Whistleblowing'.

The report handling process involves the transmission and receipt of reports either explicitly, by giving personal details, or anonymously, without revealing the whistleblower's identity.

All reports received will be treated in accordance with the law whilst offering the broadest protection of the persons concerned.

In the case of a report that is not anonymous, PhotoSì ensures the confidentiality of the identity of the person making the report ("Whistleblower") and prohibits any form of retaliation or discrimination against anyone making a report or anyone connected to it.

Anonymous reports will be taken into account if they are adequately substantiated with all the information needed to verify them, irrespective of the knowledge of the Whistleblower.

It will nevertheless be possible for the whistleblower to reveal their identity at a later date.

In order to facilitate the sending and processing of reports, an internal reporting channel is made available to the System beneficiaries, consisting of a dedicated IT platform ('Platform') via the site https://photosi.whistlelink.com/.