Orton has a dedicated system for handling whistleblowing reports, in Italy and abroad. Whistleblowing is the act of reporting suspected wrongdoing or the risk of wrongdoing. The whistleblowing management system adopted by Orton aims to achieve the following outcomes:

• encouraging and facilitating reporting of wrongdoing, demonstrating the commitment of corporate leadership to preventing and addressing it;
• supporting and protecting whistleblowers and other interested parties involved by encouraging people to come forward promptly;
• ensuring reports of wrongdoing are dealt with in a proper and timely manner, by reducing and preventing any prejudicial treatment;
• improving governance by encouraging a culture of openness, transparency, integrity and accountability; reducing the risks of wrongdoing.

Orton has set up an autonomous reporting channel that guarantees the anonymity of reports. The channel ensures that reports can be submitted in a variety of written, oral and multilingual forms. Through this channel, the report reaches Orton Whistleblowing Committee, which is responsible for the investigation and decision-making phase of the report.

• guarantee the confidentiality of the whistleblower, the intermediary, the person involved or, in any case, the persons mentioned in the report, the content of the report and the related documentation.
• allow for reporting:
  - in writing, also in computerised form through the Navex online platform, which allows the reporting person to choose between two different online reporting channels, the local one or that of the IMI Group.
  
  - orally, through a telephone line activated on the online platform operated by NAVEX Global, Inc. ("Navex") or, alternatively, through voice messaging systems on the same platform.
  
  - or, at the request of the reporting person, in a face-to-face meeting with a member of the Committee, to be arranged within a reasonable time.

The whistleblower will be given the opportunity to make the report anonymous through the Navex platform. Anonymous reports received will be treated in the same way as other reports submitted without the whistleblower's anonymity.

The Whistleblowing Committee acts with full autonomy and does not require prior authorisation to request documents, conduct interviews and/or carry out on-site inspections in connection with the investigation of reports received.

If a report concerns one of the members of the Whistleblowing Committee, the Navex platform will not automatically make the report available to that person.

Whistleblowers should use internal reporting channels to report potential wrongdoing in the first instance, provided that the reporting persons believe that the report of potential wrongdoing can be dealt with effectively within the relevant organisation and that there is no risk of retaliation.

Orton's procedure on whistleblowing can be downloaded HERE

Log in to the Management of whistleblowing reports here https://secure.ethicspoint.com/domain/media/en/gui/22119/index.html