“Whistleblowing” means a report made by persons working for Sport Fashion Service S.r.l. (“S.F.S.”) — resources who, regardless of their contractual arrangement, carry out their activities within S.F.S. or the Mittel Group — or by other persons with an interest-related relationship with S.F.S. or the Mittel Group (including, by way of example, customers, suppliers, consultants and stakeholders, including shareholders and persons performing administrative, management, control, supervisory or representative functions) who, in the course of carrying out their duties, become aware of unlawful or risky conduct that may cause harm to the organisation for which they work or prejudice the public interest.

Reports may concern, by way of example, breaches of codes of conduct; the Organisational Model pursuant to Legislative Decree 231; accounting and administrative irregularities, irregularities in accounting and tax obligations or in the preparation of the annual financial statements; false statements and false certifications; breaches of environmental, occupational health and safety, and control regulations; the promise or giving of money, goods, services or other benefits intended to corrupt suppliers, customers or public officials; actions liable to damage the reputation of S.F.S. or companies belonging to the Mittel Group; violations of human rights or privacy, harassment and discrimination; and offences falling within the scope of European Union acts.

The Mittel Group encourages the good-faith reporting of any irregularities and does not permit reports submitted for purely defamatory or slanderous purposes, or reports concerning exclusively aspects of private life with no direct or indirect connection to business activities.

Anyone who submits a report with intent or gross negligence that is subsequently found to be unfounded may be subject to disciplinary sanctions. This measure is intended to ensure responsible use of the reporting tool and prevent unjustified reports.

To submit a report, the Mittel Group has adopted a web-based IT platform called “GlobaLeaks”, which can be accessed directly via the following link: https://glks.mitteladg.it or by using the “submit a report” section below.  

The platform ensures the confidentiality of the identity of the reporting person, the reported person, any third parties or witnesses mentioned, and the facts described in the report.

The function responsible for receiving reports is the Head of Internal Audit of the parent company Mittel S.p.A. 

The Mittel Group also allows reports to be submitted anonymously, provided that they are sufficiently detailed, as set out in the adopted Whistleblowing Procedure.

Once the reporting procedure has been completed, a 16-character numerical “report code” is generated. This code must be retained and can be used to retrieve the report in order to monitor its progress or, where necessary, amend or supplement any supporting documentation.

In addition to the Platform (the recommended internal reporting channel), which is preferable because of the stronger safeguards it provides, a report may also be submitted:

By ordinary mail — addressed to the attention of the Head of Internal Audit of the parent company Mittel S.p.A., Via Borromei No. 5, 20123 Milan — following the instructions set out in the Whistleblowing Procedure;

Orally:
– Through the platform, using the specific “submit a voice report” function;

– During a direct meeting with the Head of Internal Audit of the parent company Mittel S.p.A., to be requested through the platform (specifying “request for a direct meeting” in the notes).

For general information about Whistleblowing, you may browse freely by clicking the sections below.