Annual Report on Corporate Governance (February ... - FIAT Industrial

Whistleblowers will be guaranteed, in good faith, against any form of retaliation, discrimination or penalty and, in any
case, will also be guaranteed confidentiality relative to the identity of the whistleblower, except for legal obligations and
protecting the rights of the Company and the persons accused in mala fide. The Supervisory Board also assumes the role
of Ethics Officer.
The Comments Relative to the Violation of a General Nature must be communicated without delay regarding:
– The commission of Offences or conduct that is not in line with the principles of conduct foreseen in the Code of Conduct
and/or the Legislative Decree 231/01 Program, or the internal procedures issued by the Company;
– Findings and sanctions committed by Public Entities (Internal Revenue Service, Municipal Inspection, INPS, INAIL, ARPA,
ASL, etc.) upon results from the inspection verifications;
– Criticalities that emerge over the course of the relations with Public Officials or public service employees (e.g. relative to
contributions/financing for inspections, testing, supplying installation or maintenance services, etc.);
– Deficiencies or inadequacies relative to the work locations, equipment, individual protection devices, or any other dangerous
situations related to workplace health and safety.
In addition to the reports described above, any information concerning Information Inherent to the Management of
Sensitive Processes must be immediately communicated to the Compliance Program Supervisory Board:
– Proceedings and/or notifications by judicial police departments, or any other authority, indicating investigations underway
for Offences, also in regard to unknown persons;
– Rulings regarding the application of disbursements and utilisation of government grants;
– Fequests for legal assistance submitted by Managers and/or Employees in regard to proceedings by Judicial Authorities
relative to Offences pursuant to Legislative Decree 231/2001;
– Any other information that might be useful in order to monitor and prevent offences;
– Information relative to the disciplinary proceedings executed and the eventual sanctions imposed pursuant to the Program
(including provisions toward the Employees) or archiving provisions for such proceedings with the relative motivations;
– Summarised proposals for tenders won subsequent to biddings on a national and European level, or private agreements;
– Information relative to the duties assigned to public entities or subjects that perform public utility functions;
– Periodical reports relative to workplace health and safety.
The comments relative to the violations of a general nature and the abovementioned information must be forwarded to
the Supervisory Board.
2.5 Receipt and Retention of Information
The information, communications and reports foreseen by this Program must be retained by the Compliance Program
Supervisory Board in a specific database (electronic or hardcopy) for a period of 10 years, pursuant to confidentiality and
privacy laws.
Access to the database is restricted exclusively to the members of the Board of Statutory Auditors, the Directors, the
Compliance Program Supervisory Board of Fiat Industrial and to persons delegated by the same.
3. VERIFICATION OF THE ADEQUACY OF THE PROGRAM
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