SECOND LEVEL OF CONTROL

• Compliance and Anti money laundering – Dott.ssa Giulia Sala
• Risk management – Dott. Luca Coppola

THIRD LEVEL OF CONTROL

• Internal audit - Marcello Fumagalli, BDO Italia S.p.A.

• Implementation of Law 231 requirements since inception
• Best standards on internal procedure according to regulation and at technical level (procurement, bid process, etc.)
• Click here to consult the Code of Ethics
• Click here to consult the Model 231

• Chairman – Professional Governance Overview S.r.l. - Represented by Avv. Mario Ippolito (Studio Legale Carnelutti – Milano)
• Effective member – Dott.ssa Anna Maria Allievi - President of Board of Statutory Auditors
• Effective member – Dott. Paolo E.G. Ciocca - Statutory Auditor

As to internal reports

a. in electronic form, by connecting to the portal and selecting COIMA SGR S.p.A. (for all reports except those relating to the Whistleblowing Manager)
b. in paper form, for the attention of the Compliance Department Manager — Piazza Gae Aulenti, 12, 20124 Milan MI. In view of the confidential registration of the report by the Whistleblowing Manager, it is necessary for the report to be inserted in two closed envelopes: the first with the whistle-blower's identification data and a photocopy of the identification document; the second with the report, in order to separate the whistle-blower's identification data from the report. Both envelopes must then be inserted into a third sealed envelope bearing on the outside the words "Strictly confidential. Reserved to the Whistleblowing Manager”, in order to guarantee maximum confidentiality; in case of use of this channel, the whistle-blower must indicate in the communication a postal or email address to which the Whistleblowing Manager can provide proof of receipt of the Report and provide the relevant feedback pursuant to Article 5, Legislative Decree 24/2023 as indicated below.

As to external reports

a. if destined for ANAC (for violation of European Union provisions), please refer to the internet address www.anticorruzione.it
b. if destined for CONSOB (for violations of the TUF), please refer to the internet address http://www.consob.it/web/area-pubblica/whistleblowing

• Click here to download the Whistleblowing privacy policy
• Click here to download the privacy policy on Whistleblowing