Whistleblowing - Reporting pathway

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 Far East Pte Ltd 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.

WAYS OF SENDING REPORTS

Reports can be sent directly to Company local recipients:

• In writing:

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;

by mean of local dedicated “safe box”, such as a physical metal / carton box placed in the premises of the Company (2^nd Floor Office Stationery Area, 1^st Floor Canteen Area, Warehouse Admin Area), aimed at containing communications in paper and handled by the Local Whistleblowing Officer / Team (as locally appointed).

• Orally:
  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.

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 Far East Pte Ltd appointed as Local Whistleblowing Officer the following:

-        Finance & Admin / Finance Manager

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.

The verification of the validity of the Reports will be carried out according to the following procedure.

PRELIMINARY CHECKS AND INVESTIGATION

The Report is always received by the Local Whistleblowing Officer (either directly or through communication flow from the Corporate Whistleblowing Committee) which is a dedicated person / team part of the Local Subsidiary.

Upon reception of the Report, the Local Whistleblowing Officer must promptly (i.e., within the following working day or at the earliest) inform via e-mail the Corporate Whistleblowing Committee of the Report received and the Corporate Whistleblowing Committee may share the information according to necessity.

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 of Mapei Far East Pte Ltd.

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., GDPR Regulation and local implementing legislation for EU Countries, etc.).