THE ORGANIZATIONAL MODEL FOR CRIME PREVENTION

Legislative Decree No. 231/2001 introduced into the Italian legal system a form of liability for legal entities, classified as administrative but essentially criminal in nature, for certain types of crimes committed in the interest or to the advantage of the Company, by its directors and employees, as well as by persons acting in the name and on behalf of the Company.

In compliance with the provisions of Legislative Decree No. 231/2001, Tremagi Energia srl ​​and Tremagi srl (the Group’s holding company) have begun the process of risk analysis pursuant to the aforementioned decree, defining strategic guidelines and adopting, respectively, an Organization, Management, and Control Model (MOGC) and a Code of Ethics shared with its subsidiary Illumia spa.



Whistleblowing

In compliance with Legislative Decree 24 of March 10, 2023, the Tremagi Group has adopted an online reporting platform for each Group company affected by the legislation, including anonymous reporting. This platform allows all interested parties (employees, company personnel, third parties collaborating with the company, etc.) to combat illegality through active and responsible participation. This tool may be used to submit reports regarding behaviors by Group Company Personnel in violation of the Code of Ethics, laws, regulations, provisions of the Authorities, internal regulations, and Model 231.

The identity of reporting parties is guaranteed by the utmost confidentiality in accordance with the legislation, and the information and personal data communicated as part of the report are processed solely for its analysis and management.

Without prejudice to the preferential use of the reporting channels made available by the Tremagi Group, in the cases expressly indicated pursuant to art. 6 of Legislative Decree 24 of 10 March 2023, it is also possible to make a report to the competent authority (ANAC).