System for reporting illegitimate behaviours – Whistleblowing

Tages Capital SGR is committed to promoting a corporate culture based on ethical behaviour and good corporate governance, thus fostering an environment in which people are encouraged to report unacceptable or non-compliant conduct.

The reporting system is available to all people who operate in the work context, both internal and external to the SGR, thus including all those who have had/have/will have a legal relationship with the SGR.

For this reason, specific channels, processes and procedures have been established in Tages Capital SGR to ensure that reports are managed in a timely, efficient manner and according to standards of maximum confidentiality and protection of the reporter, in compliance with Legislative Decree 24/23.

Violations and/or irregularities relating to the following issues and to external regulations may be reported:

violations, potential or actual, regarding the prevention of money laundering and terrorist financing
violations, potential or actual, relating to the provision of investment services
violations, potential or actual, of national or European Union regulatory provisions that harm the public interest or the integrity of the public administration or private entity, relevant pursuant to Legislative Decree 231/2001;
violations of the Codes of Conduct adopted by the SGR.

The reporting system described does not apply to:

disputes, claims or requests linked to a personal interest of the reporting party which relate exclusively to his/her individual working relationships;
reports of violations concerning behaviours, acts or omissions of which the Reporter or the complainant became aware in a context other than the work context;
complaints from customers, as well as complaints from third parties (i.e. counterparties, suppliers) which may arise in the execution of the contract or in the context of the management of a dispute.

Reports must be submitted using one of the following channels:

Recipient	Reporting channel
Responsible for the internal reporting system – WB Manager	in written by registered letter (“without return receipt”), addressed to: Tages Capital SGR S.p.A. Corso Venezia 18, 20121 MilanoAtt. to: Head of Compliance – Daniela Provenzano “PRIVATE AND CONFIDENTIAL” requesting a direct meeting with the Head of Compliance – Daniela Provenzano ph. +39 02 873371
Backup function (to be activated exclusively in cases in which the WB Manager is the alleged person responsible for the violation or has a potential interest related to the report such as to compromise the impartiality of the judgment)	in written by registered letter (“without return receipt”), addressed to: Tages Capital SGR S.p.A. Corso Venezia 18, 20121 MilanoAtt. to: Head Risk Management – Luca Barbieri “PRIVATE AND CONFIDENTIAL” requesting a direct meeting with the Risk Management – Luca Barbieri ph. +39 02 873371

Recipient

Reporting channel

Responsible for the internal reporting system – WB Manager

in written by registered letter (“without return receipt”), addressed to:
Tages Capital SGR S.p.A.
Corso Venezia 18,
20121 MilanoAtt. to: Head of Compliance – Daniela Provenzano
“PRIVATE AND CONFIDENTIAL”
requesting a direct meeting with the Head of Compliance – Daniela Provenzano ph. +39 02 873371

Backup function

(to be activated exclusively in cases in which the WB Manager is the alleged person responsible for the violation or has a potential interest related to the report such as to compromise the impartiality of the judgment)

in written by registered letter (“without return receipt”), addressed to:
Tages Capital SGR S.p.A.
Corso Venezia 18,
20121 MilanoAtt. to: Head Risk Management – Luca Barbieri
“PRIVATE AND CONFIDENTIAL”
requesting a direct meeting with the Risk Management – Luca Barbieri ph. +39 02 873371

External reporting channels

Tages Capital SGR encourages employees to make use of internal channels as a priority, without prejudice to the possibility of making an external report to ANAC, Bank of Italy and Consob, for the areas of their respective competence and if particular conditions arise:

*National Anti Corruption Authority (ANAC)*
The reporting person can make an external report to ANAC if, at the time of its submission, one of the following conditions occurs: – he/she has already made an internal report and it has not been followed up; – he/she has reasonable grounds to believe that, if he/she made an internal report, it would not be followed up effectively or that the same report could lead to a risk of retaliation; – he/she has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest. Furthermore, the Reporting person can also contact ANAC to notify any retaliatory acts resulting from a report.
Recipient	Reporting channel
ANAC	External reports may be made accessing the institutional website of the entity: https://www.anticorruzione.it/-/whistleblowing

National Anti Corruption Authority (ANAC)

The reporting person can make an external report to ANAC if, at the time of its submission, one of the following conditions occurs:
– he/she has already made an internal report and it has not been followed up;
– he/she has reasonable grounds to believe that, if he/she made an internal report, it would not be followed up effectively or that the same report could lead to a risk of retaliation;
– he/she has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest.
Furthermore, the Reporting person can also contact ANAC to notify any retaliatory acts resulting from a report.

Recipient

Reporting channel

ANAC

External reports may be made accessing the institutional website of the entity:

https://www.anticorruzione.it/-/whistleblowing

*CONSOB and BANCA D’ITALIA*
Reports can be made pursuant to art. 4-duodecies of the Consolidated Finance Act (TUF) “Reporting procedure to the Supervisory Authorities” This possibility is offered to the staff of the subjects indicated in the art. 4-undecies of the TUF. The way to be followed to transmit reports directly to Consob and the Bank of Italy by the SGR’s staff is indicated in the sections of the respective sites.
Recipient	Reporting channel
Consob	External reports may be made accessing the institutional website of the entity: http://www.consob.it/web/area-pubblica/whistleblowing;
Banca d’Italia	External reports may be made accessing the institutional website of the entity: http://www.bancaditalia.it/compiti/vigilanza/whistleblowing

All reports are treated with the maximum level of confidentiality and in any case the confidentiality and protection of the personal data of the reporting party and of any reported party is guaranteed.

Reporters in good faith are guaranteed and protected against any form of retaliation, discrimination or penalisation, regardless of the subjects involved.