WHISTLEBLOWING SYSTEM

(c.d. "Whistleblower System")

Overview

Eurocar Italia manages an independent and confidential whistleblowing system, administered by the Volkswagen Group's Central Investigation Office, to report potential violations by employees and suppliers.

A fundamental pillar of our Whistleblowing System is the principle of procedural fairness. It also ensures the maximum possible protection of Whistleblowers, the persons involved, and employees who contribute to the investigation of reported misconduct.

This also includes the opportunity to make anonymous reports and communications. We ensure that no procedures are carried out to identify anonymous whistleblowers who do not abuse our Whistleblowing System. Retaliation against whistleblowers and all persons contributing to investigations will not be tolerated. Reported persons are considered innocent until the violation is proven. Investigations will be conducted with the utmost confidentiality, and information will be handled in a fair, prompt, and protected process.

How do we process your report?

Qualified and experienced colleagues from the Central Investigation Office thoroughly examine each report of potential misconduct by a Volkswagen Group employee and systematically follow it up. First, you will receive an acknowledgment of receipt. The Central Investigation Office then evaluates your report. This includes gathering information on the facts, particularly from the whistleblower.

Only if this initial assessment shows reasonable suspicion of a violation will an investigation be initiated by a dedicated Investigation Unit. Subsequently, the results of the investigation will be evaluated by the Central Investigation Office, and appropriate measures will be recommended. Information on the status and outcome of the procedure will be provided to you without undue delay.

Potential violations of the Code of Conduct for Business Partners, including serious risks and violations of Human Rights and the Environment by direct and indirect suppliers, can also be reported to the Central Investigation Office. The Central Investigation Office will inform the competent offices, which will handle the matter accordingly. This includes, in particular, taking the necessary measures to minimize or end the violations and/or risks.

You can find information here on the process rules applicable to the Volkswagen Group's Complaint Procedure: https://www.volkswagen-group.com/de/publikationen/weitere/rules-of-procedure-for-the-volkswagen-group-complaints-procedure-2007

* Processing time varies depending on the subject of the procedure

Do you have concerns or complaints about a product or service from Eurocar Italia Group?

In case of questions, requests, or complaints related to the purchase of new or used vehicles or concerning service activities carried out at one of the Eurocar Italia Group Dealerships or regarding services possibly provided by our Business Partners, we ask you to contact the reference staff directly or address the request to the contacts indicated in the "Contacts" section. We are confident of your understanding that the Whistleblowing System does not handle such topics.

Reporting Channels

The Whistleblower System offers various channels to report potential misconduct by employees, allowing for a quick review and reaction by our company, if necessary. However, this does not affect the legal right to contact the designated authorities as described below.

24/7 Hotline

Available all year round, contacts downloadable from the website. https://goto.speakup.report/en-GB/phs/phone-numbers

Online Platform

Secure and multilingual system for reporting.

Link: https://goto.speakup.report/phs

Organization Code: 122333

Ombudsperson

External lawyers providing confidential advice. https://www.ombudsmen-of-volkswagen.com/

Email

You can contact the Central Investigation Office via email: io@volkswagen.de

Postal Address

Volkswagen AG, Ufficio d'Indagine Centrale
Mailbox 1717
Berliner Ring 2
38436 Wolfsburg (Germany)

Personally

You can contact the Central Investigation Office by email at the following address: io@volkswagen.de

SpeakUp App

Mobile reporting via QR code.

QRCode to automatically enter the organizational code PHS, necessary when the app is opened for the first time:

Supervisory Body of Eurocar Italia

Alternatively, a report can also be addressed to the Supervisory Body of Eurocar Italia, reachable via email at the address: odv@eurocar.it.*

Do you have further questions, or do you need a local contact?

Questions or suggestions for improving the Whistleblowing System can also be addressed to the Central Investigation Office. Additionally, for all matters related to the Whistleblowing System, the Porsche Holding Compliance Department can be contacted via email at hinweis@porsche.co.at or the local Compliance Officer at whistleblowing@eurocar.it.

Do you have other questions or need a local contact?

Questions or suggestions for improving the Whistleblowing System can also be addressed to the Central Investigation Office.

If you have been interviewed as part of an investigation, you have the opportunity to leave your feedback by contacting the Ombudspersons, as an independent body.

Additionally, for all matters related to the Whistleblowing System, our Compliance Officer can also be contacted by sending an email to the following address: whistleblowing@eurocar.it

Canale di segnalazione esterno dell’Autorità Nazionale Anti-Corruzione

In attuazione della Direttiva (UE) 2019/1937, è stato emanato il D.Lgs. n. 24 del 10 marzo 2023 riguardante “la protezione delle persone che segnalano violazioni del diritto dell'Unione e recante disposizioni riguardanti la protezione delle persone che segnalano violazioni delle disposizioni normative nazionali”, il quale introduce l’istituzione di un canale di segnalazione esterno gestito dall’Autorità Nazionale Anti-Corruzione (ANAC). È possibile effettuare la segnalazione, alle sole condizioni previste dalla normativa, accedendo al portale dei servizi ANAC al seguente link: Whistleblowing - Autorità Nazionale Anti-Corruzione (https://www.anticorruzione.it/-/whistleblowing).

Notes

* Information on communication management It is informed that communications sent to the address odv@eurocar.it are managed in total autonomy and confidentiality by the company's Supervisory Body established pursuant to Legislative Decree no. 231/01. To ensure maximum protection of data and personal information, it is noted that the management and storage system resides on Microsoft servers and access to the dedicated email box is exclusive to the Supervisory Body (direct recipient and manager) and protected by confidential credentials not shared with any other department, function, or person in the company (e.g., IT, Management, or Compliance).