API spa has adopted an own Organizational and Management Model or “231 Model”, so-called because pursuant to Italian Legislative Decree No. 231 of 8th June 2001.

Decree No. 231 made companies liable for certain crimes perpetrated in their interest or to their advantage by persons acting in their name or on their behalf such as directors, managers, employees and also by persons acting in a consultancy capacity when their actions are under the control or management of persons employed by the companies themselves.

The purpose of the 231 Model is therefore to prevent the committing of the crimes described in the Decree.

API spa is part of the RPM inc Group and adopts the principles of the Group Code of Conduct "The values ​​& expectations of 168".

With a view to compliance with the relevant legislation (Legislative Decree 24/2023), the Company adopts a whistleblowing system through which it is possible to report to the relevant bodies, in a confidential and protected manner, any offenses discovered during one's work activity.

The main useful information relating to the reporting methods and channels, as well as the management of the reports themselves, is provided below.

THE REPORTS

Reports consist of oral communications of information on violations, or behaviors, acts or omissions that harm the public interest or the integrity of the Company and which are attributable to:

unlawful conduct relevant pursuant to Legislative Decree 231/2001 or violations of the 231 Organizational Models and the Code of Ethics;

offenses that fall within the scope of application of the European Union or national acts indicated in the annex to Legislative Decree 24/2023 or of the national acts that constitute the implementation of the European Union acts indicated in the annex to the (EU) Directive 2019/1937, although not indicated in the annex to the Decree, relating to the following sectors: public procurement; financial services, products and markets and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental Protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; protection of privacy and protection of personal data and security of networks and information systems;

conduct that harms the financial interests of the European Union;

conduct concerning the internal market, which compromises the free movement of goods, people, services and capital;

acts or omissions that defeat the object or purpose of the provisions of the European Union in the sectors mentioned in the previous points.

Where the reporting person is not willing to disclose his or her identity, reports are also accepted anonymously, if detailed and adequately documented.

METHOD OF SUBMITTING AND RECIPIENTS OF THE REPORT

Reports can be made via the following reporting channels:

in oral form: via voice messaging system connected to a telephone line specifically created and reachable by following the instructions on this page: LINK 

Reports made via the channels mentioned are received and managed directly by a dedicated and specifically trained team.

The reporting person can also make an external report, through the channels activated by the National Anti-Corruption Authority (ANAC) and/or a public disclosure (e.g. via the press or social media), benefiting from the protection provided for internal/external reports if , if, at the time of its presentation or public disclosure (depending on the case), one of the conditions provided for by Legislative Decree no. occurs. 24/2023.

PROTECTION AND RESPONSIBILITY OF THE REPORTER

The Company ensures protection from any form of retaliation, for reasons connected directly or indirectly to the report, against the whistleblowers who report in good faith and of all the subjects interested and/or involved in the report (for example: facilitators, colleagues or relatives of the whistleblowers, subjects with knowledge of the facts reported, etc.).

The identity of the reporting person and any other information from which such identity can be deduced, directly or indirectly, cannot be disclosed without the express consent of the reporting person himself, to persons other than those competent to receive or follow up on the reports, expressly authorized to process such data, and without prejudice to legal obligations.

Sanctions are foreseen against those who violate the whistleblower protection measures.

Protections are not guaranteed and sanctions are provided against the reporting person, where possible, in the case of reports made with intent or gross negligence which turn out to be false and unfounded, with defamatory content or in any case made for the sole purpose of damaging the Company, the reported person or subjects interested/involved by the report. The Company reserves the right to undertake appropriate initiatives also in legal matters.

PROTECTION OF THE REPORTED

During the verification and investigation of possible violations, the individuals subject to the reports could be involved or notified of this activity but, in no case, will a proceeding be initiated solely because of the report, in the absence of concrete evidence regarding the content of it. This could possibly happen based on other evidence found and verified starting from the report itself.