In compliance with Italian Legislative Decree 10 March 2023 n. 24, Panini S.p.A. has implemented a Platform for sending and managing whistleblowing reports.

This Platform can be reached at the link:

The Platform is accessible to anyone (employees, partners, customers, suppliers, consultants, non-employee collaborators and, more generally, any third party) for sending reports regarding:

● Illegal conduct pursuant to Italian Legislative Decree no. 231/2001

● Violations of the Organization and Management Model and of the Code of Ethics adopted by Panini S.p.A. pursuant to Italian Legislative Decree no. 231/2001 (these documents are available here www.paninigroup.com/en/us/code-of-ethics),

● Criminal, administrative, civil and accounting offenses that fall under EU laws

● Regular or irregular acts or omissions which defeat the object or purpose of EU laws

● Regular or irregular acts or omissions aimed at obtaining undue tax advantages

● Acts or omissions concerning the internal market, which compromise the free circulation of goods, people, services and capital (Article 26, paragraph 2, TFEU).

The reporting Platform complies with the ANAC (Italian national anti-corruption authority) provisions on whistleblowing and guarantees maximum respect for confidentiality of the reporting subjects and of the facts reported.

In order to ensure the highest level of confidentiality for their identities, PANINI staff are prohibited from accessing the Whistleblowing Platform using PANINI-owned devices that are connected to PANINI-owned internet networks.

Access to the Whistleblowing Platform via corporate devices connected to non-corporate internet networks, or via personal devices connected to corporate internet networks, does not guarantee complete anonymity as it leaves browsing log traces. Therefore, PANINI strongly advises against accessing the Whistleblowing Platform in these ways. Anyone who chooses to proceed in this manner should be aware of the potential risks and will assume full responsibility.

PANINI staff are provided with all the necessary information and instructions to access the Whistleblowing Platform using their own devices and internet networks. This ensures the utmost privacy of their personal data.

Members of the Organismo di Vigilanza (the Supervisory Body of Panini S.p.A) will be responsible for the management of whistleblowing reports.

They are required to liaise with whistleblowers exclusively through the Platform, with a view to ensure their anonymity. Therefore, it is recommended to use the Platform as the only tool for sending reports.