WhistleBlowing

In compliance with Legislative Decree no. 24 of 10 March 2023, Panini S.p.A. provides a platform for the submission and management of whistleblowing reports, which can be accessed through the following link:

The platform is accessible to anyone (employees, partners, customers, suppliers, consultants, collaborators, associates and, in general, any third party) to send reports regarding

● Illegal behaviour relevant under Legislative Decree no. 231/2001

● Violations of the Organisational and Management Model adopted by Panini SpA pursuant to Legislative Decree no. 231/2001 and violations of the Code of Ethics adopted by Panini SpA (these documents are available at this link www.paninigroup.com/en/us/code-of-ethics),

● Criminal, administrative, civil and accounting offences covered by EU law

● Regular or irregular acts or omissions that defeat the object or purpose of EU law

● Regular or irregular acts or omissions to obtain undue tax advantages

● Acts or omissions relating to the internal market that jeopardise the free movement of goods, persons, services and capital (Article 26(2) TFEU).

The whistleblowing platform complies with the ANAC rules on whistleblowing and guarantees the utmost confidentiality of the reporting parties and the facts reported, including by computer.

In order to guarantee the maximum confidentiality of the identity of the whistleblower, PANINI employees and employees of PANINI's subsidiaries and affiliates are strongly discouraged from accessing the Whistleblowing Platform using the Company's own devices connected to the Company's Internet network, including the one provided and managed by PANINI for PANINI's subsidiaries and affiliates.

Access to the Platform through Company devices connected to non-Company Internet networks, or through personal devices connected to Company Internet networks, does not guarantee complete anonymity, nor does it guarantee equivalent measures to protect confidentiality, because through the navigational data processed by the PANINI security systems for the protection of the information system, in compliance with the regulations in force.

For this reason, PANINI recommends that the Platform be accessed exclusively through personal devices and outside the company's Internet network. In the case of reports sent through the Platform without adopting the protective measures described above, it will not be possible to guarantee an equivalent level of confidentiality to the Reporters: in such cases, the Reporters declare that they are aware of this and therefore assume all responsibilities.

The management of the reports will be the responsibility of the Panini S.p.A. Supervisory Body and the Audit function, which will be required to use the platform to interact with the reporters and send any requests for clarification. It is therefore recommended that the Platform be used preferably as an internal channel for sending reports.