Whistleblowing

The present Policy is a first attempt for the Mapei Group and its Subsidiaries operating worldwide to face this topic of increasing importance as well as internationally dealt with by many legal systems.

For this purpose, the General Manager of Mapei Indonesia issued the present Policy and appointed the Local Whistleblowing Officer / Team, as described below in the document.

The main aspects treated in this Policy are summarized below and will be detailed more in depth in the following parts of this document:

• Creation of a dedicated internal channel for receiving Reports from whistleblowers;
• Dedicated internal channel must be safe, secured and privacy compliant (e.g. data treated in compliance with GDPR and / or local data protection regulations);
• Guarantee the anonymity of the whistleblower and its protection against acts of retaliation;
• Clear and defined timing for managing the Report and giving feedback to the whistleblower;
• Disclosure on the External Authorities involved (for external reports, if foreseen by the local legislation). 

METHOD OF SUBMISSION AND RECIPIENTS OF THE REPORT

Reports can be sent directly to Company local recipients:

1. using the online Whistleblowing Portal made available by the Subsidiary on its internet website, which provides a guided questionnaire for the Whistleblower; the Whistleblowing Portal can be reached at https://whistleblowing.mapei.com/ and then it must be selected the box of the Company for which the Report will be submitted;
2. through the local dedicated electronic mailbox – [email protected] addressed and handled by the Local Whistleblowing Officer / Team;
3. in printed form, by ordinary mail addressed to the Local Whistleblowing Officer / Team, at the Local Subsidiary office address;

1. using the online Whistleblowing Portal made available by the Subsidiary on its internet website, which provides the possibility to send an anonymous voice message; the Whistleblowing Portal can be reached at https://whistleblowing.mapei.com/ and then it must be selected the box of the Company for which the Report will be submitted;
2. by phone and/or in person to the Local Whistleblowing Officer / Team.

Alternatively, reports concerning all the topics covered by this Policy (including the ones mentioned in the Code of Ethics) can be sent directly to the attention of the Headquarters using the WB Portal, by clicking to the button “Click here if you want to submit a report directly to the Headquarters”, since this is a centralized channel, addressed to and handled by the Corporate Whistleblowing Committee.

It should be noted that the paper form, by regular mail, and the Whistleblowing Portal are the best ways aimed at fully guaranteeing the possible anonymity of the Whistleblower.

The access to the Whistleblowing Portal is in fact subject to a “no-log” policy in order to prevent the identification of the Whistleblower who wishes to remain anonymous: this means that the company's computer systems are not able to identify the access point (IP address) even if you are logged in from a computer connected to your corporate network.

For each Report submitted, the Portal assigns a unique identification code that allows each Whistleblower to check its progress, anonymously. Similarly, if a Report is not adequately detailed, the Recipients (identified in the next paragraph) have the right to request the Whistleblower, using the Portal and always through that code, further details of what is reported. 

MANAGEMENT OF REPORTS

Mapei Group established a set of rules for managing Reports, specifically aimed at guaranteeing appropriate, timely and accurate management of the latter, in compliance with the present Policy.

The General Manager of Mapei Indonesia appointed as Local Whistleblowing Officer / Team the following:

• Finance Manager & HR Responsible

Also, it has been created a dedicated body for managing Reports, the Corporate Whistleblowing Committee, composed by independent members from Corporate Departments such as Corporate Internal Audit and HR & Organization, with support of Legal Department, upon necessity.

Timing

The Report must be managed within a predefined timeframe, to which Mapei complies by setting forth the following deadlines:

• acknowledgment of receipt of the report to the reporting person is set within seven days of that receipt;
• a reasonable timeframe to provide feedback, not exceeding three months from the acknowledgment of receipt or, if no acknowledgement was sent to the reporting person, three months from the expiry of the seven-day period after the report was made.

REPORTED RIGHTS

This Policy fully complies with the provisions of Law No 13 of 2006 and its amendment, Law No 31 of 2014 on the topic of the reported protection rights.

Also, any specific instruction given at local level concerning the reported protection, in accordance with local legislation and its scope of application, is valid and applicable.

During the investigation and the verification of potential non-compliance, individuals who are the subject of the Reports may be involved or notified of this activity, but under no circumstances a procedure will be initiated solely based on the Report, in the absence of concrete evidence on its allegations. A procedure could be initiated only on the basis of evidence other than allegations made in the Report itself.

DATA PROTECTION AND DATA STORAGE

The supporting documentation pertaining the Report is archived, safely and for a period of two years after the closing of the Report, by the Local Whistleblowing Officer / Team of Mapei Indonesia.

Any personal and sensitive information contained in the Report, including those relating to the identity of the Whistleblower or other individuals, must be processed in accordance with the applicable rules for the protection of personal data, as established by any local applicable legislation (e.g., Indonesia’s PDP Law No. 27/2022 and GDPR Regulation for EU data subjects, etc.).