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WHISTLEBLOWING DISCLOSURE

Work & Progress S.p.A. (hereinafter, "Owner") provides you with the information pursuant to Article 13 of Regulation (EU) 2016/679 (hereinafter, "GDPR"), d.lgs 196/2003 and d.lgs 101/2018 in relation to the processing of personal data, in compliance with the principles of lawfulness, correctness, transparency and minimization of data, concerning the procedure for reporting hypothetical unlawful conduct (also pursuant to art. 54 bis, d.lgs 165/2001), transmitted through the dedicated section on the institutional web page or the further modalities provided for and communicated on the website.

DATA CONTROLLER

The data controller of personal data is Work & Progress S.p.A.

PURPOSE AND LEGAL BASIS

Your personal data will be processed for the management of all stages of the Whistleblowing process, including but not limited to: collection of the report through the digital channel set up on the institutional website or the other modalities provided and communicated, verification of the merits of the alleged unlawful conduct that is the subject of the report, in-depth investigations, investigative activities, adoption of consequential measures, initiatives to involve the Judicial Authority, and protection of rights. The legal basis for processing is the legitimate interest of the Data Controller as well as the fulfillment of a legal obligation.

AUTHORIZED AND RESPONSIBLE CONTROLLERS, RECIPIENTS OF YOUR DATA

Your personal data will be processed by the law firm PTBM of ABBIATEGRASSO that has a role in the management of the Whistleblowing procedure, previously authorized to process and specially instructed and trained (by way of example: staff, external consultants involved in the management). All are strictly bound by the obligation not to disseminate or disclose any personal data of which they become aware. The processing will be done through almost exclusively computerized mode, but there is a residual and minimal need to process data also in paper form for any reports received as an alternative to the digital channel set up and dedicated on the institutional website. The data may also be processed by external parties, possibly also as autonomous Data Controllers, or formally appointed by the Data Controller as Responsible Parties ex art. 28 GDPR, by way of example: the providers of the platform for Whistleblowing management (for technical management purposes), other recipients of your data could be, the Judicial Authority, the Court of Auditors, ANAC, as well as all parties in obedience to the fulfillment of a legal obligation.

DATA RETENTION PERIOD

Personal data will be kept by the Company until the purposes and related legal requirements are fulfilled. Reports of facts not covered by the Whistleblowing procedure, will be retained for the time stipulated in the regulations. For the cases of reports that should be verified and not filed, because they are well-founded, the retention period is identified as 10 years from the end of the planned corrective actions, as well as the time necessary for the management of all related activities. A longer retention time is always provided if it is necessary to fulfill a legal obligation or experience the protection of a right in court.

DATA TRANSFER TO NON-EUROPEAN COUNTRIES

The Company does not transfer your data to countries outside the European Economic Area.

RIGHTS OF INTERESTED PARTIES

As a data subject, you are entitled to your rights under Articles 15/22 of the GDPR; to exercise them, you may contact the Data Controller or the DPO at the contact details as indicated above. There is always a right to file a formal complaint with the Data Protection Authority at: www.garanteprivacy.it

TO ACCESS THE PLATFORM CLICK HERE.

To access the platform and make the report, type:

ID: reporter_W&P

PASSWORD: beacon_W&P

Once you log in, the platform will provide you with a new ID (NICKNAME) and force you to choose a new password.

In this way she is guaranteed anonymity.

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