What can be reported

Reports should be, above all, as substantiated as possible and provide as much information as possible, in order to enable the Companies to carry out the necessary enquiries and checks.

There is no exhaustive list of offences or irregularities that may be the subject of whistleblowing. Reports that concern reasonable and well-founded evidence of unlawful or irregular conduct or alleged offences, whether committed or attempted, that harm the public interest or the integrity of public administration or the private entity, and of which the reporter has become aware in the context of their work, are considered relevant.

These reports may concern, for example:

• administrative, accounting, civil or criminal offences.

• violations of European regulations concerning transportation safety, protection of the environment, radiation protection and nuclear safety, food and feed safety and animal health and well-being, public safety, consumer protection, private life and personal data protection, and information system and network safety.

• violations of competition and State aid law.

• non-compliance with the corporate values and rules of conduct described in the Company Group Code of Ethics.

• violations of the disciplinary codes of SACBO SpA and BGY International Services Srl.

• violations, requests or inducement to violate laws, regulations or company procedures, regarding the activities and interests of the companies.

• episodes of passive corruption (to the detriment of the Companies and in the interest of an individual or third party) and/or episodes of active corruption (to the benefit of the Companies) as well as incitement to corrupt.

• violations of the Organisational, Management and Control Models of SACBO SpA and BGY International Services Srl, also as a result of behaviour that poses a risk of committing an offence/irregularity as provided for by said Organisational Models.

• reprehensible findings, irregularities and conduct.

• violations of confidentiality obligations.

Reports may not contain information on:

1) grievances of a personal nature on the part of the whistleblower or requests concerning the execution of the employment relationship or relations with the hierarchical superior or colleagues, for which reference should be made to the Human Resources Department.

2) violations that are obligatorily governed by national or EU laws or by national laws constituting implementation of European Union laws.

3) breaches of national security, or regarding contracting relating to national defence or security, unless these aspects fall under the relative secondary European Union law.

Anonymous reports, i.e., those made without identification of the whistleblower, may also be taken into account, provided that they are adequately substantiated and made in extensive detail, i.e., when they are able to bring to light facts and situations relating them to specific contexts.

Reports may not contain information on grievances of a personal nature on the part of the whistleblower or requests concerning the execution of the employment relationship or relations with the hierarchical superior or colleagues, or complaints regarding services offered in the terminal. For the latter, please refer to https://www.milanbergamoairport.it/it/reclami

By way of example, the following is a list of the different types of offences that can be selected when creating a report:

✓ Corruption and incitement to corrupt.

✓ Theft.

✓ Mobbing.

✓ Absenteeism.

✓ Violent behaviour or harassment.

✓ Violation of the Group Code of Ethics.

✓ Conflict of interest (Group personnel may not have any economic or financial interests, other than those of the Company, in business with customers, suppliers and competitors in any capacity).

✓ Disclosure of confidential information/breach of confidentiality obligations.

✓ Use of money, goods or benefits of unlawful origin, receiving stolen goods.

✓ Violation of laws, regulations and company procedures, with reference to the activities and interests of BGY International Services Srl.

✓ Violation of MOGC 231/2001 and annexed Disciplinary Regulations.

✓ Violation of environmental rules/procedures.

✓ Violation of occupational safety rules/procedures.

✓ Violations of European legislation on transport safety, environmental protection, radiation protection and nuclear safety, public health, consumer protection.

✓ Privacy and data protection, network and information system security.

✓ Violations of competition and State aid law.

✓ Other (e.g., abuse, illicit behaviour, etc.).