1. Scope

Jobrapido S.r.l. (« Jobrapido » or « Company« ), in accordance with Legislative Decree No. 24/2023 (« Whistleblowing Decree« ), has established its own Internal Reporting Channels to prevent and counteract illicit behaviors, regulating their use by potential Whistleblowers within a specific policy (« Whistleblowing Policy » or « Policy« ).

The administrative body of Jobrapido has entrusted the management of the Internal Reporting Channels to the Whistleblowing Committee (« Committee« ), as an autonomous internal office, dedicated and specifically trained for receiving and managing Internal Reports related to the Company. The Whistleblowing Committee is composed of the Head of the HR Department of the Company, designated as President, and other permanent employees of the HR Department.

The present regulation (« Internal Reporting Management Regulation – Whistleblowing » or « Regulation« ) respectively governs:

• The functions and powers of the Committee in the management of Internal Reports;
• The terms and methods for managing the Internal Reporting Channels in accordance with the Whistleblowing Decree.

For matters not specifically provided for here, reference is made to the Whistleblowing Policy adopted by the Company and the Whistleblowing Decree.

2. Internal Reporting Channels and Restricted Access to the Whistleblowing Committee

Reports can be made in written or oral form through the Internal Reporting Channels described in the Whistleblowing Policy (see § 6), to which reference is made.

Access to the management of the Internal Reporting Channels is and shall remain reserved solely for the members of the Committee, except as determined by them or otherwise provided for in the Whistleblowing Policy, this Regulation, or pursuant to provisions of the Whistleblowing Decree.

Upon receipt of an Internal Report, the Committee must handle and document it in accordance with the procedures set forth in the Whistleblowing Policy (see § 7), to which reference is made, and as detailed below.

2.1. Training

The Committee is trained in the use and management of the Internal Reporting Channels in compliance with the Whistleblowing Policy, this Regulation, the Whistleblowing Decree, as well as in accordance with all current and applicable laws regarding the protection of personal data.

3. Powers of the Committee in relation to the management of Internal Reports

With regard to the management of Internal Reports, the Committee is empowered to verify the substantiation of the reported Violations and to carry out subsequent verification activities.

In particular, in compliance with the provisions and obligations provided by the Whistleblowing Decree, as well as the provisions and limits provided by applicable labor laws, the Committee may:

• Interact with the Whistleblower to request any additional information regarding the reported matters.
• Request and acquire company information and documents.
• Conduct interviews with individuals who may provide relevant information for the verification of the reported Violations.
• Utilize translation services in case of receiving Reports in a language other than Italian.
• Utilize the support of other internal company functions for investigative activities useful for verifying the reported Violations.
• Engage external consultants to conduct or support the conduct of investigations and assessments regarding the legal relevance of the facts, circumstances, and behaviors subject to Reporting, considering applicable laws, also to assess and verify whether the reported Violations fall within the objective scope of the Whistleblowing Decree.

In accordance with company procedures and approved levels of authorization, the Committee is guaranteed financial coverage by the Company if necessary for the performance of Internal Reporting management activities, with the obligation of timely reporting. The Company reserves the right to annually evaluate any changes to the financial management mentioned above.

4. Steps for the Management of Internal Reporting Activities

Upon receipt of an Internal Report, the Committee must follow the procedural steps for management described below.

4.1. Receipt Acknowledgment of the Internal Report

. The Committee must send the Whistleblower a receipt acknowledgment of the Report within 7 (seven) days from the date of receipt of the Report.

If the Internal Report is submitted in written form, the Committee sends the acknowledgment of receipt to the Whistleblower through the Online Platform.

If the Report is made orally, the Committee provides the Whistleblower with the acknowledgment of receipt either directly in person (delivering a short-handwritten note confirming receipt, of which the Committee keeps a copy), or via email if the Whistleblower has provided their email address for contact (in cases where the oral Report is made through a telephone line or video conference).

4.2. Follow-Up to the Internal Report

The Whistleblowing Committee is required to diligently follow up on the received Report in order to assess its admissibility and verify the relevance, scope, and potential risks arising from the reported facts

4.2.1. Preliminary Assessment of Admissibility

The Whistleblowing Committee must preliminarily ascertain that:

• The Whistleblower falls within the categories of legitimate individuals authorized to submit Internal Reports and protected under the Whistleblowing Decree (see § 4, Whistleblowing Policy).
• The Violation falls within the objective scope of the Whistleblowing Decree (see § 2, Whistleblowing Policy),
• The Report is related to the Whistleblower’s work context, is not of a personal nature, and is aimed at protecting the integrity of Jobrapido.

If the preliminary assessments are positive, the Committee proceeds with the substantive analysis of the content of the Report.

If, on the other hand, at least one of the preliminary assessments is negative, the Committee declares the Report inadmissible and orders its archiving without conducting further substantive investigative activities.

The decision to archive must be communicated to the Whistleblower within the legal timeframe. If possible, the Committee indicates to the Whistleblower the competent parties for handling such Report to whom they may address. In any case, if the Report declared inadmissible concerns particularly serious matters, the Committee informs the relevant internal authorities.

4.2.2.   Substantive Assessment

If the Internal Report is deemed admissible, the Committee examines the facts presented by the Whistleblower and any supporting documentation attached to verify their validity, conducting appropriate internal investigations.

The activities to verify the validity of the reported facts are carried out in accordance with the principles of impartiality and confidentiality, conducting any activities deemed appropriate by the Committee.

In particular, within these verifications, and in compliance with the provisions and limits provided by applicable labor laws, the Committee may:

• Interact with the Whistleblower who has provided their contact information for further information or clarification.
• Request information from individuals mentioned in the Report as being aware of the facts and who may provide useful input for the investigation.
• Acquire documents.
• Conduct interviews with employees, managers, and administrators of Jobrapido.

Following the internal investigations, the Committee, with the support of other internal functions or appointed consultants (see § 4.2.2.1.), prepares a final report of the activities carried out and their outcomes.

4.2.2.1. Sharing of Internal Reports

During its investigations, the Committee may involve the relevant corporate functions to conduct necessary inquiries and make subsequent determinations and measures as needed.

The Committee may also seek the collaboration of external consultants with the necessary professionalism and independence if the received Report requires, in its judgment, legal, fiscal, or specialized expertise.

The sharing of Internal Reports must occur in a manner that ensures the confidentiality of the Whistleblower’s identity, the Involved Individuals mentioned in the Report, and any Facilitators, in compliance with the Whistleblowing Decree, GDPR, Privacy Code, and/or other applicable laws regarding the protection of personal data. In particular, the Committee must not disclose the Whistleblower’s identity without their consent or may disclose it only after obtaining a commitment to confidentiality from the involved third party, where revealing the Whistleblower’s identity is essential for fact-finding. To this end, the Committee has the involved third party sign the Confidentiality Commitment Declaration as outlined in Appendix A to this Regulation.

4.2.3. Archiving

The Committee archives the Internal Report if:

• It is inadmissible, in which case the Committee must assess the possibility of forwarding the Report to other competent corporate functions or bodies, particularly if it concerns significant violations for the protection of Jobrapido’s integrity and may inform the Whistleblower accordingly.
• It is clearly unfounded due to the absence of factual elements justifying further investigation.
• It has a generic content that does not allow understanding of the facts, and the Whistleblower has not provided contact information for further clarification or, even if contacted by the Committee, has refused to provide them.
• It is accompanied by inappropriate or irrelevant documentation.
• The Committee determines that the Report was made by the Whistleblower with malice (bad faith) or gross In this case, the Committee reserves the right to propose to the relevant corporate functions or bodies the initiation of a disciplinary proceeding against the Whistleblower, if the legal requirements are met, in accordance with the provisions of the Whistleblowing Policy.

The Committee communicates the archival decision and the reasons for such decision to the Whistleblower through the online platform, within the legal deadlines.

4.2.4.   Proposal of Remedial and/or Improvement Actions and Related Verification

Where archiving is not provided, upon completion of the veracity checks, the Committee proposes to the relevant corporate functions the necessary remedial and/or improvement actions concerning the reported Violation, in accordance with the existing and applicable corporate procedures, as well as in compliance with the pertinent provisions regarding confidentiality and personal data protection referenced in this Regulation. By way of example, these actions may consist of:

• Proposing disciplinary or legal actions in civil, administrative, or criminal courts against those responsible for the Violation, where the conditions exist and in accordance with applicable laws;
• Proposing contractual measures as a consequence of the identified Violations, where the conditions exist and in accordance with applicable laws and agreements contained in the relevant contracts;
• Modifications to corporate procedures.

Subsequently, the Committee also verifies that the proposed remedial and/or improvement actions have been implemented and, in the absence of the adoption of such actions or remedial measures, the underlying reasons for their non-adoption. In the case of an unjustified failure to adopt the proposed remedial and/or improvement actions, the Committee informs the administrative body of Jobrapido.

4.3. Feedback to the Whistleblower

Within 3 (three) months from the date of receipt of the notice or, in the absence of such notice, within 3 (three) months from the expiry of the 7 (seven) days deadline from the submission of the Report, the Committee must provide feedback to the Whistleblower regarding the Report.

The feedback consists of communicating information about the follow-up given or intended to be given to the Report and is sent by the Committee to the Whistleblower through the online platform.

Il riscontro consiste nella comunicazione di informazioni relative al seguito che viene dato o che si intende dare alla Segnalazione e viene inviato dal Comitato al Segnalante tramite la Piattaforma on-line.

The information provided to the Whistleblower must not violate the rights of others, including the rights to privacy and the protection of personal data of the Involved Individuals or mentioned in the Report, and must be considered strictly confidential. In the feedback communication, the Committee must highlight the strictly confidential nature of the contained information.

If the verifications of validity require more than 3 months, the Committee may provide an interim feedback to the Whistleblower, still through the online platform, and postpone the communication of the final outcome of the investigation to a later time.

5. Conservation of Procedure Documentation

Upon concluding all necessary inquiries and providing feedback to the Whistleblower, the Committee archives and preserves the Reports (including Anonymous ones) as well as the documents, reports, transcripts, and minutes related to them in a dedicated and access-restricted repository, within the timelines and methods specified by the Whistleblowing Policy (see § 7), to which reference is made.

6. Reporting of Activities and Information Flows to Corporate Bodies

The Committee, at least annually, provides the corporate administrative body of the Company with summary information regarding the managed Reports, excluding the identifying data of the Whistleblowers and any Facilitators.

7. Independence and Conflict of Interest

The Committee is required to operate independently in relation to both the Whistleblower and the Involved Individual.

In cases of conflicts of interest, where the received Report concerns a Violation attributed to a member of the Whistleblowing Committee, the subsequent verifications will be entrusted to the CFO of the Company.

However, if a member of the Whistleblowing Committee wishes to submit a Report, they must do so through the Internal Channels adopted by Jobrapido, except in cases of conflict of interest as mentioned above. In such cases, the Report must be addressed to the CFO of the Company.

When involved, the CFO must handle the Report in compliance with the confidentiality obligation provided by the Whistleblowing Decree and after signing the Declaration of Commitment to Confidentiality attached to this Regulation as Annex A.

8. Role of Privacy of Committee Members in Handling Internal Reports

In relation to the management of Internal Reporting Channels, with the appointment on 15/04/2024 the Committee members have been designated as data processors/authorized data processors in accordance with the Privacy Code, GDPR, and any other applicable laws regarding the protection of personal data.

9. Treatment of Personal Data

Any processing of personal data carried out in relation to what is provided in this Regulation, including the exchange and transmission of personal data between the Committee and other subjects authorized to receive them under the Regulation itself and within the limits allowed by law, must be carried out in accordance with the Whistleblowing Decree, the Privacy Code, GDPR, and/or other laws on the protection of personal data applicable

Personal data that is evidently not useful for the processing of a specific Report will not be collected or, if collected accidentally, must be promptly deleted and in any case in compliance with company procedures and applicable laws regarding the retention period of data.

10.  Confidentiality Obligations

The Committee also has the duty to keep confidential the assistance provided to the Whistleblower by any Facilitators involved in the Report.

Reports cannot be used by the Committee – and by other parties involved in their management – beyond what is necessary to give them proper follow-up.

The identity of the Reporter, and any other information from which their identity can be directly or indirectly inferred, cannot be disclosed without their express consent to persons other than those who are part of the Committee or those involved in the management of the Report, subject to a written commitment to confidentiality.

The Committee also has a duty to keep confidential the assistance provided to the Reporter by any Facilitators involved in the Report.

11. Prohibition of Retaliatory Acts and Reporting to the Administrative Body of Jobrapido

Any form of Retaliation, direct or indirect, against the Reporter is strictly prohibited.

Without prejudice to what is provided in the Whistleblowing Policy, the Committee is required to promptly report to the administrative body of Jobrapido any information concerning any possible Retaliation (including threats and attempts of Retaliation) against the Reporter, of which the Committee itself becomes aware, so that the necessary measures and actions can be taken.

12. Interactions with the ANAC and with institutions, bodies, organizations, and authorities competent under the Whistleblowing Decree

In all cases where the ANAC or institutions, bodies, organizations, and authorities competent under the Whistleblowing Decree (together with ANAC, « Authorities« ) need to interact with the members of the Whistleblowing Committee, the latter, in coordination with the administrative body of Jobrapido, will provide the necessary support and cooperation to the Authorities, in compliance with the procedures and rules of conduct provided by the Company and in strict compliance with all applicable laws.

Information, documents, and personal data may be shared with the relevant Authorities in compliance with the Whistleblowing Decree and other applicable laws in the specific case.

13.  Adoption and Compliance with the Regulation

The present Regulation, drafted by the Whistleblowing Committee, was approved by the administrative body of Jobrapido on 15/04/2024.