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Whistleblowing Policy

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The following definitions apply in this Policy:

  1. “Report”: the provision of information about breaches of this Policy to the
    Report Receipt and Follow-up Officer (R.R.F.O.) of the Company.
  2. “Person concerned”: a natural or legal person who is named in the report as a person to whom the breach is attributed or with whom the person to whom the breach is attributed is associated, where the breach falls within the scope of this Policy.
  3. “Reporting person”: the natural person who makes a report, providing information about breaches which he or she obtained in a work-related context.
  4. “Retaliation”: any direct or indirect act or omission which occurs in a work-related context, causes or may cause unjustified detriment to the reporting person, or places him or her at a disadvantage, and is connected with a report.
  5. “Reasonable grounds”: the justified belief of a person with similar knowledge, training and experience to the reporting person that the information they hold is true and constitutes a breach of Union law that falls within the scope of this Policy.
  6. “Feedback”: the provision to reporting persons of information on the action envisaged or taken as follow-up and on the grounds for such follow-up.
  7. “Work-related context”: current, past or prospective work activities in the Company, irrespective of the nature of those activities, through which persons obtain information about breaches and within which those persons may suffer retaliation if they report them.
  8. “Breaches”: acts or omissions that are unlawful under Union law or
    defeat the object or the purpose of the rules of Union law that fall within the material scope of this Policy.
  9. “Information on breaches”: information, including reasonable
    suspicions, about breaches which have been committed or are very likely to
    be committed in the Company, as well as information about attempts to conceal
    breaches.
  10. “Report Receipt and Follow-up Officer” or “R.R.F.O.”: the Officer responsible for the
    receipt and follow-up of reports on breaches that fall within the scope of this Policy, whose duties are assigned to the head of the Core Regulatory Compliance Function.
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