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In accordance with the Legislative Decree No. 24 of 10 March 2023, “Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council, of 23 October 2019 which introduces the obligation for all the companies or entities which have employed used, in the last calendar year, with more than 50 employees to set up an internal a33> internal reporting platform, commonly referred to as, known as Whistleblowing.
LAGITRE SRL Via Venezia Giulia, 10 20157 Milan (MI) VAT No. and Tax Code 04804230151
tel. 02 38001360 email lagitre@lagitre.com
provides a reporting platform configured to comply with current legislation in accordance with the guidelines issued by Confindustria. This platform is made available to those authorised to use it and who are therefore able to submit a report:
Reports can also be made:
The whistleblowing platform provided is intended to:
What to report
Breaches relating to acts (of any nature, including mere omissions) committed by persons associated with LAGITRE SRL, which may concern:
In order to assist the Whistleblower in identifying matters that may be reported, the following is a list of relevant breaches and/or conduct, provided by way of example only and is neither exhaustive nor binding:
Reports must relate to facts of which the Whistleblower is aware, and the Whistleblower must have reasonable grounds to believe that the information reported is true at the time of reporting. Reports must be made promptly after the facts come to light, so as to make verification practically possible. The following do not constitute whistleblowing reports: complaints, claims or requests linked to the Whistleblower’s personal interests that relate exclusively to their individual employment relationship, or to their relationship with their superiors; communications or complaints relating to commercial activities or services to the public.
What to report
You must log in to the AntaresWB platform via the link https://lagitre.antareswb.it, available on the LAGITRE SRL website. Click on the “Submit a report” button. You will then be required to enter your personal details and provide a copy of your identity document. You will then need to provide a description of the breach you wish to report, the date or period to which it relates, where the breach occurred, how you are involved in the report, whether you have reported the facts to other organisations or individuals, and any other relevant details. Reports cannot be submitted anonymously. The platform offers a guided process in which certain fields, marked with a red asterisk, are mandatory. Each report will be assigned a code. This code will allow the reporter to retrieve the reports they have submitted and check the responses received. Please note that this code is unique and cannot be duplicated. If lost, you will need to resubmit the report, stating in the description that it is a duplicate made necessary by the loss of the original code.
Milan (MI), 15 December 2025
1. Processing of personal data
2. Purpose of this policy
This notice explains the nature of your personal data being processed, the purposes and methods of processing, any recipients of such data, and the rights to which you are entitled.
3. Purposes and lawfulness of processing
Your personal data will be used for the purpose of collecting and managing reports (so-called whistleblowing) relating to conduct that may constitute one of the predicate offences set out in Legislative Decree 231/2001, where applicable, as well as breaches of the relevant organisational model or other unlawful conduct or conduct that is otherwise contrary to company policies; for the subsequent conduct of the internal investigation and for the imposition of disciplinary or contractual measures against the person responsible for the unlawful acts or irregularities, including the possible reporting of such offences to the judicial authorities. The Company processes personal data in compliance with regulatory obligations and, in particular – should you be an employee of the Company – in compliance with Law 179/2017 protecting those who report offences or irregularities of which they become aware in the course of their employment. In particular, personal data is used for the following specific and legitimate purposes:
In addition, your personal data will be processed for the purpose of carrying out all activities that are instrumental, ancillary or otherwise necessary to the achievement of the aforementioned purposes.
4. Nature of the contribution
The processing of your personal data is necessary for the purposes set out in paragraph 3 above. The provision of your personal data is mandatory for the performance of the activities referred to in paragraph 3 above; any refusal to provide such data will make it impossible to follow up on your report.
5. Legal basis for processing
With regard to the processing of personal data carried out by the Company:
6. Dati personali oggetto di trattamento
1. Categories of data processed
Your general personal data, such as identifying details (name, address or other personal identification details), will be processed. Special categories of personal data, such as information on racial and/or ethnic origin, religious and/or ideological beliefs, trade union membership or sexual orientation, will not be processed. Given the presence of free-text fields on the Platform, you may voluntarily provide such special categories of personal data. With regard to the personal data of the individuals subject to reporting, it will not be necessary to provide them with any information, given that the processing is carried out either (i) for the purpose of asserting or defending a right of the Company in court or (ii) for the purpose of pursuing the public interest in the prosecution of criminal conduct.
2. Any processing of data beyond the categories specified
The Company may, however, need to request and process personal data in addition to those falling within the categories set out above, for the same purposes as those set out in paragraph 3 above, provided that the provision of such additional data is:
7. Data retention periods
Your personal data will be retained for as long as is necessary to carry out the investigation. Should the investigation confirm the validity of the report, your data will be retained until appropriate measures have been taken against the person responsible for the reported offences or irregularities. Once these activities have been completed, your personal data will be deleted or anonymised.
8. How we use your data
9. Data flow
10. Data controller
The Data Controller is LAGITRE SRL, Via Venezia Giulia 10, 20157 Milan (MI), VAT No. and Tax Code 04804230151, tel. 02 38001360, email lagitre@lagitre.com
11. Data Protection Officer
The Company is not required to appoint a Data Protection Officer (also known as a “DPO”).
12. Exercising your rights
Where the conditions are met and within the limits set out in the applicable legislation, you may exercise the following rights in relation to the processing of your personal data: (i) the right of access to personal data and information regarding its processing; (ii) the right to rectification where personal data is inaccurate or incomplete; (iii) the right to have your personal data erased; (iv) the right to object to the processing of your personal data; (v) the right to restrict the processing of your personal data; (vi) the right to have your personal data transferred to other companies or organisations and/or to receive your personal data in a structured, commonly used and machine-readable format. The above rights may be exercised by contacting lagitre@lagitre.com. Should you identify any irregularities in the processing of your personal data, you may lodge a complaint with the Data Protection Authority, in accordance with the procedures set out on the Authority’s website (www.garanteprivacy.it).
In accordance with the Legislative Decree No. 24 of 10 March 2023, “Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council, of 23 October 2019 which introduces the obligation for all the companies or entities which have employed used, in the last calendar year, with more than 50 employees to set up an internal a33> internal reporting platform, commonly referred to as, known as Whistleblowing.
LAGITRE SRL Via Venezia Giulia, 10 20157 Milan (MI) VAT No. and Tax Code 04804230151
tel. 02 38001360 email lagitre@lagitre.com
provides a reporting platform configured to comply with current legislation in accordance with the guidelines issued by Confindustria. This platform is made available to those authorised to use it and who are therefore able to submit a report:
Reports can also be made:
The whistleblowing platform provided is intended to:
What to report
Breaches relating to acts (of any nature, including mere omissions) committed by persons associated with LAGITRE SRL, which may concern:
In order to assist the Whistleblower in identifying matters that may be reported, the following is a list of relevant breaches and/or conduct, provided by way of example only and is neither exhaustive nor binding:
Reports must relate to facts of which the Whistleblower is aware, and the Whistleblower must have reasonable grounds to believe that the information reported is true at the time of reporting. Reports must be made promptly after the facts come to light, so as to make verification practically possible. The following do not constitute whistleblowing reports: complaints, claims or requests linked to the Whistleblower’s personal interests that relate exclusively to their individual employment relationship, or to their relationship with their superiors; communications or complaints relating to commercial activities or services to the public.
What to report
You must log in to the AntaresWB platform via the link https://lagitre.antareswb.it, available on the LAGITRE SRL website. Click on the “Submit a report” button. You will then be required to enter your personal details and provide a copy of your identity document. You will then need to provide a description of the breach you wish to report, the date or period to which it relates, where the breach occurred, how you are involved in the report, whether you have reported the facts to other organisations or individuals, and any other relevant details. Reports cannot be submitted anonymously. The platform offers a guided process in which certain fields, marked with a red asterisk, are mandatory. Each report will be assigned a code. This code will allow the reporter to retrieve the reports they have submitted and check the responses received. Please note that this code is unique and cannot be duplicated. If lost, you will need to resubmit the report, stating in the description that it is a duplicate made necessary by the loss of the original code.
Milan (MI), 15 December 2025
1. Processing of personal data
2. Purpose of this policy
This notice explains the nature of your personal data being processed, the purposes and methods of processing, any recipients of such data, and the rights to which you are entitled.
3. Purposes and lawfulness of processing
Your personal data will be used for the purpose of collecting and managing reports (so-called whistleblowing) relating to conduct that may constitute one of the predicate offences set out in Legislative Decree 231/2001, where applicable, as well as breaches of the relevant organisational model or other unlawful conduct or conduct that is otherwise contrary to company policies; for the subsequent conduct of the internal investigation and for the imposition of disciplinary or contractual measures against the person responsible for the unlawful acts or irregularities, including the possible reporting of such offences to the judicial authorities. The Company processes personal data in compliance with regulatory obligations and, in particular – should you be an employee of the Company – in compliance with Law 179/2017 protecting those who report offences or irregularities of which they become aware in the course of their employment. In particular, personal data is used for the following specific and legitimate purposes:
In addition, your personal data will be processed for the purpose of carrying out all activities that are instrumental, ancillary or otherwise necessary to the achievement of the aforementioned purposes.
4. Nature of the contribution
The processing of your personal data is necessary for the purposes set out in paragraph 3 above. The provision of your personal data is mandatory for the performance of the activities referred to in paragraph 3 above; any refusal to provide such data will make it impossible to follow up on your report.
5. Legal basis for processing
With regard to the processing of personal data carried out by the Company:
6. Dati personali oggetto di trattamento
1. Categories of data processed
Your general personal data, such as identifying details (name, address or other personal identification details), will be processed. Special categories of personal data, such as information on racial and/or ethnic origin, religious and/or ideological beliefs, trade union membership or sexual orientation, will not be processed. Given the presence of free-text fields on the Platform, you may voluntarily provide such special categories of personal data. With regard to the personal data of the individuals subject to reporting, it will not be necessary to provide them with any information, given that the processing is carried out either (i) for the purpose of asserting or defending a right of the Company in court or (ii) for the purpose of pursuing the public interest in the prosecution of criminal conduct.
2. Any processing of data beyond the categories specified
The Company may, however, need to request and process personal data in addition to those falling within the categories set out above, for the same purposes as those set out in paragraph 3 above, provided that the provision of such additional data is:
7. Data retention periods
Your personal data will be retained for as long as is necessary to carry out the investigation. Should the investigation confirm the validity of the report, your data will be retained until appropriate measures have been taken against the person responsible for the reported offences or irregularities. Once these activities have been completed, your personal data will be deleted or anonymised.
8. How we use your data
9. Data flow
10. Data controller
The Data Controller is LAGITRE SRL, Via Venezia Giulia 10, 20157 Milan (MI), VAT No. and Tax Code 04804230151, tel. 02 38001360, email lagitre@lagitre.com
11. Data Protection Officer
The Company is not required to appoint a Data Protection Officer (also known as a “DPO”).
12. Exercising your rights
Where the conditions are met and within the limits set out in the applicable legislation, you may exercise the following rights in relation to the processing of your personal data: (i) the right of access to personal data and information regarding its processing; (ii) the right to rectification where personal data is inaccurate or incomplete; (iii) the right to have your personal data erased; (iv) the right to object to the processing of your personal data; (v) the right to restrict the processing of your personal data; (vi) the right to have your personal data transferred to other companies or organisations and/or to receive your personal data in a structured, commonly used and machine-readable format. The above rights may be exercised by contacting lagitre@lagitre.com. Should you identify any irregularities in the processing of your personal data, you may lodge a complaint with the Data Protection Authority, in accordance with the procedures set out on the Authority’s website (www.garanteprivacy.it).