At Humans S.R.L. we have introduced our Whistleblowing Policy with the aim of establishing guidelines for reporting situations related to:

• Behaviours, acts or omissions that harm the public interest or undermine the integrity of the public administration or private body, as defined by Legislative Decree 24/2023.

We encourage each member of our community to be vigilant and promptly report behavior that they deem to be improper or unacceptable. This approach allows us to put an immediate end to such behaviours and to take appropriate action towards the perpetrators.

Our policy governs every step of the reporting process, including:

Making the report.
Receipt of the report and its subsequent acceptance.
The overall management of the report.
Making decisions on the report itself.

The implementation of a Whistleblowing system reflects our commitment to realising principle no. 16 of the UN Global Compact, dedicated to “Peace, Justice and Solid Institutions”. This highlights our determination to promote ethical behaviour, accountability and transparency within our organisation, thus contributing to the construction of a healthy working environment that complies with global standards.

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• Those who entertain with Humans S.R.L. – regardless of salary – an employment, consultancy, collaboration, supply, volunteering or internship relationship.
• Those applying or intending to apply, probationary employees or former employees.
• Persons with administrative, management, control and supervisory or representative functions.

These subjects will be called Creator.

The following Policy applies to reports of violations provided for by the Whistleblowing Decree, namely:

1. administrative, accounting, civil or criminal offences;
2. unlawful conduct, relevant pursuant to Italian Legislative Decree no. 231/2001 or violations of organisational models.
3. offences falling within the scope of EU or national acts relating to the following areas: 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 and animal health and welfare; public health; consumer protection; protection of privacy and protection of personal data and security of networks and information systems;
4. Acts or omissions that harm the financial interests of the EU protected pursuant to art. 325 TFEU.
5. Acts or omissions concerning the internal market, referred to in art. 26 (2) TFEU, including breaches of EU competition and state aid rules, as well as corporate taxes.
6. Acts or conduct that defeat the object or purpose of the provisions of EU acts in the areas indicated in numbers 3), 4) and 5).

In addition, the Policy also applies to reports of conduct, acts or omissions that represent or may represent violations of the moral code of Humans S.R.L. and related company policies.

The report consists of the communication of the unlawful conduct specified in art. 2.1, through the platform specifically prepared by Humans S.R.L. and accessible at the following link, which can also be found on the company website https://humans.tech/ .

The platform can be used both to make reports pursuant to the Whistleblowing Decree and to report violations of the moral code and internal policies. The whistleblower will be able to choose between the categories available depending on the offence to be reported. At the same time, it must describe the situation being reported and may attach photos or other documents in support of it.

The report can also be made in voice form, by recording an audio message. Reporting can be done confidentially or anonymously. If you choose the confidential form, the identity of the reporter will only be known to the staff in charge of managing the report and will appear anonymous and confidential to others during the processing of the report.

Identity will not be disclosed to others within the organisation without the consent of the data subject and consent to transparency about identity will only be required if it is necessary for the internal processing of the report.

If you choose to report anonymously, anonymity is guaranteed as follows:

• If you decide to make the report in writing, simply check the box relating to anonymity and no data such as the name and surname are requested; the email will also not be shown to the person handling the report.
• If you decide to report orally, you can choose anonymity and the voice is changed so that it is not recognizable.

Once the report has been made, a code is provided, which is essential to be able to follow the course of the report and to be able to communicate with those who manage the report. In addition, it is essential to keep your chosen personal password.

Reports, whether they concern the offences provided for by the Whistleblowing Decree or violations of company policies, must:

• Be carried out in good faith.
• Be based on clear and consistent details.
• Relate to facts that can occur and that are known directly.
• Contain, if known, all the information necessary to identify the perpetrators of the potentially unlawful conduct.

The whistleblower must make reports based on the belief that what is stated is true, regardless of whether what is reported is then reflected in the insights that follow.

Therefore, reports that are manifestly unfounded, opportunistic or made for the sole purpose of damaging the reported subject or subjects in any case interested in the report are not taken into consideration and may involve actions before the competent Judicial Authority and possibly the imposition of sanctions by the latter.

For reports that fall within the scope of the Whistleblowing Decree (listed in point 2.1 of this policy), additional channels and specific protections are available to protect and support the person making the report.

Pursuant to the Whistleblowing Decree, the whistleblower may also use the external reporting channel in the following cases:

• If you have already made an internal report and it has not been followed up.
• has reasonable grounds to believe that, if it were to make an internal whisleblowing, the whistleblow would not be effectively followed up or that the whistleblow might lead to the risk of retaliation;
• the whistleblower has reasons for believing that the violation may constitute an imminent or clear threat to the public interest. The external channel is established by ANAC and can be found at the following link: https://whistleblowing.anticorruzione.it/#/.

The whistleblower may also make a public disclosure of the relevant offence pursuant to the Whistleblowing Decree if:

• Has already made an internal and external report or has made an external report directly, without being given feedback within the established deadlines.
• the whistleblower has reasons for believing that the violation may constitute an imminent or clear threat to the public interest.
• the whistelblower has reasonable grounds for believing that the external report may carry the risk of retaliation, or may not have been followed up properly due to the specific circumstances of the particular case. This would include instances where evidence may have been concealed or destroyed, or when there is a well-founded fear that the person who received the report may be colluding with the perpetrator or involved in the violation itself.

Public disclosure is intended to bring information about violations into the public domain through the press, electronic media or other means of dissemination capable of reaching a large number of people (e.g. TV, social networks, etc.).

The reporter cannot be retaliated against for having made a report, that is, by way of example:

• Dismissal, suspension (including from training) or equivalent measures.
• Demand (demotion) or no promotion.
• Change of duties, transfer, salary reduction, changes to working hours.
• Negative notes of merit.
• Several negative references.
• Disciplinary measures.
• Coercion, intimidation, harassment or ostracism.
• Discrimination or any unfavourable treatment.
• Failure to convert or renew a fixed-term employment contract into a permanent employment contract (in case of legitimate expectation of conversion).
• non-renewal or early termination of a fixed-term employment contract;
• damage, including to a person’s reputation, particularly on social media, or economic or financial harm, including loss of economic opportunities and loss of income;
• Blacklisting.
• early conclusion or cancellation of the contract for the supply of goods or services;
• cancellation of a license or permit;
• the request to undergo psychiatric or medical examinations.

In the event that an act that represents retaliation is carried out, such act is to be considered null and void. Those who have made the report must contact the ANAC, which can also make use of the National Labour Inspectorate. To obtain the declaration of nullity of the retaliatory acts, it is necessary to contact the Judicial Authority.

The Whistleblowing Decree provides for the protection of those who also report support measures, that is, forms of information, assistance and advice free of charge on the methods of reporting and protection from retaliation, on the rights of the person involved, as well as on the methods and conditions of access to legal aid.

The list of Third Sector entities that provide support measures to those who report is established at the ANAC. The list can be consulted at this link: https://www.anticorruzione.it/-/whistleblowing#p3.

The Whistleblowing Decree provides specific protection measures for the reported subject, guaranteeing the confidentiality of his identity and those involved until the conclusion of the proceedings deriving from the report itself. This protection remains in place until the report is closed.

In line with this principle, Humans S.R.L. has decided to extend these guarantees also to the subject reported for violations other than those contemplated by the Whistleblowing Decree, such as violations of related internal policies.

In all circumstances, Humans S.R.L. guarantees the reported party the right to be promptly informed of the accusations and any disciplinary measures taken against him, as well as the right to exercise his defence.

Depending on the category in which the report falls, it may be managed by the HR Team (hereinafter “report management team”), guaranteeing confidentiality and data protection. The report management team, therefore, pursuant to the Whistleblowing Decree, gives confirmation within 7 working days to the person who made the report of receipt of the same and its taking charge.

The reporting team may need to carry out further investigations, if the report is critical, and then ask for specifications from the reporting party: in this case, using the platform’s internal chat, they can communicate, if they wish, while maintaining anonymity.

Following the assessment, the report management team may believe that the report is not relevant or actionable. The report cannot be processed in these cases:

• Lack of evidence
• Cases manifestly unfounded.
• Cases relating to conduct or facts that do not constitute a violation of the Whistleblowing Decree or company policies.

In the event of irrelevance or inadmissibility of the report, the report management team communicates the outcome to the person who made the report.

If, on the other hand, the report is considered relevant, it is possible that the report management team will carry out further investigations, involving the company functions concerned.

In addition, if deemed necessary or appropriate, the reporting team may:

• Contact the person who made the report, asking for clarification or to provide documents and/or other evidence.
• Hear and contact others who may be involved or informed.
• 
All the activities carried out in the in-depth and preliminary phase are recorded and tracked.

At the end of the in-depth analysis, the team responsible for managing the report draws up a report summarising the activities carried out and the final assessment. In the event that the report is unfounded, it is filed, and the person who reported it is informed of the outcome.

If, on the other hand, it emerges that the report has been submitted in bad faith, the team responsible for managing the report informs the HR team for the adoption of the necessary measures, in accordance with current law and the Collective Bargaining Agreement.

In addition, if the conditions are met, the reporting team may report the incident to the competent Judicial Authority.

In the event that the report is well-founded, the report management team communicates the situation to the HR team and the Board, who make the necessary decisions, respecting current legislation and the Collective Bargaining Agreement.

In situations where the offences found are presumed to constitute offences, civil, accounting or administrative offences, the reporting team may also inform the competent Judicial Authority. The decision on the report is made within a period of 3 months, in accordance with the times established by the Whistleblowing Decree.

The HR Team prepares, every six months, a summary report of the reports received and presents it to the Board and the Board of Statutory Auditors.

This report includes the results of the reports, the underlying reasons, the indication if they are reports pursuant to the Whistleblowing Decree or for violations of the Policies, together with any measures taken.

Humans S.R.L. intends to offer training to all members of the Team regarding the Whistleblowing Decree and reports in general. The goal is to ensure that each Creator gains awareness of the ways, purposes, and importance of reporting wrongdoing

Our HR Team documents each report and maintains a detailed register within the Reporting Register, which has been specially established in electronic format within our platform dedicated to reports. All related documentation is kept in full compliance with privacy regulations.

To ensure maximum protection of personal data, only those strictly necessary for the processing of a specific report are collected and stored. Personal data that is clearly not relevant to such processing is not collected or stored.

Any personal data provided during the reporting process is kept for the period of time necessary to manage the report and verify its validity. In any case, this period never exceeds one year from the filing of the report, at the end of which the data is deleted.

If disciplinary and/or judicial proceedings are instituted following the report, the data may be kept for the entire duration of the procedure and a further 10 years after its conclusion.

When submitting the report, the whistleblower is required to read thePrivacy Policy and provide their consent to the processing of data.

This process ensures transparency and awareness regarding the handling of personal data within our Whistleblowing system.

Our policy and the related whistleblowing platform are subject to periodic reviews to ensure constant alignment with current regulations, as well as to adapt to operational needs and experience accumulated over time.