Compliance

NTC has always been particularly attentive to the prevention of risks that could compromise the responsible and sustainable management of its business and, in line with its mission and its internal control system, to the possibility of knowing critical situations and correcting them, consolidating the relationship of trust with stakeholders.

To this end, to guarantee fairness and transparency in the conduct of business and activities carried out and to protect the corporate position and image, NTC has set up a special internal channel to receive reports of violations of internal or external regulations (as more detailed in the dedicated company directive (Directive P50 - NTC "Whistleblowing System" as amended and supplemented by the WB Parrot reporting procedure), ensuring compliance with the regulatory provisions of Legislative Decree no. 24 of 10 March 2023 on whistleblowing and on "Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law and laying down provisions concerning the protection of persons who report breaches of the national regulatory provisions", as well as the indications provided by ANAC on the subject.

To the extent that anonymity and confidentiality can be enforced according to the law, the internal reporting channel activated by NTC guarantees the confidentiality of the identity of the whistleblower (where communicated), the identity of the reported person and/or any third parties mentioned in the report, the content of the report, as well as the documents related to it, at every stage of the report management process. 

The subjects who can report (Whistleblowers) and who enjoy protection in the event of reporting are:

• legal representatives, shareholders, directors, managers, even if these functions are exercised on a purely factual basis;

• members of NTC control bodies;

• NTC employees (whatever the legal and contractual framework of the service, including trainees, volunteers);

• third parties, natural or legal persons such as, by way of example but not limited to, collaborators, self-employed workers, freelancers, consultants, suppliers, contractors and sub-contractors;

• other parties who have contractual relationships with NTC such as collaborators, business partners and/or – in any case – anyone acting in the name, on behalf or in the interest of NTC.

Employees also include candidates for employment with NTC and those whose employment contracts have already ended or have not yet started to run.

Adequate safeguards are ensured for reporting parties, in particular, with reference to the confidentiality of identity and the confidentiality of the information contained in the report, from the time of taking charge and during all phases of the management of the report, within the limits provided for by the legislation.

The identity of the reporting person and any other information from which this identity may be inferred, directly or indirectly, may not be revealed, without the express consent of the whistleblower, to persons other than those competent to receive or follow up on the reports and express forms of protection of the identity of the whistleblower are provided for by law.

No form of retaliation (e.g., dismissal, suspension, failure to promote, demotion, etc.), discrimination or penalization against the whistleblower or anyone who took part in the investigation, for reasons directly or indirectly related to the report, is allowed. If you believe you have suffered retaliation due to the report, you can report it to the National Anti-Corruption Authority (ANAC) through the IT platform managed by the same, accessible at the link: https://whistleblowing.anticorruzione.it/#/

It should be noted that the protection granted to the whistleblower is also extended to those subjects who could be the recipients of retaliation, even indirectly, due to the role assumed within the reporting process, and/or the particular relationship that binds them to the whistleblower (so-called protected subjects) and, in particular, to:

• facilitators: natural persons who assist the whistleblower in the reporting process, operating within the same work context and whose assistance must be kept confidential;

• people from the same work context as the whistleblower, and who are linked to him by a stable emotional or kinship bond within the fourth degree;

• work colleagues of the reporting person who work in the same working context as the same and who have a habitual and current relationship with that person;

• entities owned - exclusively or in majority participation by third parties - of the whistleblower or for which the whistleblower works.

Reports may concern any information on violations, to be understood as behaviors, acts or omissions that harm the integrity of NTC and which consist of:

• Violations of applicable national or European Union legislation;

• Relevant unlawful conduct pursuant to Legislative Decree no. 231 of 8 June 2001 (so-called "Decree 231 predicate offenses") or violations of NTC's Model 231 (which includes violation of the Porsche Code of Conduct for employees, the Porsche Code of Conduct for Business Partners and/or internal policies/procedures/guidelines/operating instructions);

• Any form, threat or attempt to retaliate against the whistleblower and/or protected subjects;

• Conduct aimed at concealing the aforementioned violations.

Reports must:

1. be made in good faith;

2. be detailed and based on precise and consistent facts;

3. concern facts that can be verified and known directly by the reporting party;

4. contain all the information necessary to identify the perpetrators of the reported facts or conduct and any useful information to describe the subject of the report.

Forms of "abuse" such as manifestly unfounded, opportunistic and/or made with the sole purpose of damaging the reported person, and any other hypothesis of improper or instrumental use of the reporting mechanism are prohibited and are subject to sanctions and/or actions before the Judicial Authority.

In the event of slanderous or defamatory reports, the whistleblower in bad faith may be called to answer in criminal proceedings and disciplinary proceedings may be initiated against him.

Disputes, claims or requests related to a personal interest of the reporting person that relate exclusively to their individual employment relationships, or inherent to their employment relationships with hierarchically superior figures, cannot be reported and, where reported, will not be taken into consideration.

Online platform

Reports can be transmitted (both in written and oral form, providing one's personal details and contact details or anonymously), through the online reporting channel (platform) activated by NTC accessible by all whistleblowers at the following link homehttps://nardotechnicalcenter.parrotwb.app/ managed by a specialized external service provider.

NB. In order to ensure the confidentiality of the Whistleblower's identity, it is advisable to report using a device that is in no way traceable to the company reality (NTC/Porsche company assets) and not to use the internet connection (cable or Wi-Fi) provided by NTC/Porsche. In addition, in order to ensure greater protection of your privacy, it is recommended to use systems such as "TOR Browser".

At the request of the whistleblower, forwarded through the online Platform, the report can also be made through a direct meeting, set within a reasonable time of the respective request.

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The use of the internal reporting channel is to be understood as preferred, as this channel is closer to the origin of the issues subject to the report and promptly managed.

The management of the internal reporting channel is entrusted to NTC's Local Compliance Officer - an autonomous and dedicated internal subject, specifically trained for the management of the reporting channel - who:

• issues the reporting person with acknowledgement of receipt of the report within 7 (seven) days from the date of receipt;

• maintains a dialogue with the whistleblower, who may be requested, if necessary, for further information;

• diligently follow up on the reports received, according to the principles of confidentiality, timeliness and impartiality, evaluating the report received and arranging the necessary checks aimed at ascertaining whether, on the basis of the elements in its possession, a violation has actually occurred;

• will provide feedback to the report within 3 (three) months from the date of the acknowledgement of receipt or, in the absence of such notice, within 3 (three) months from the expiry of the term of 7 (seven) days from the submission of the report.

Should the report relate to facts and/or conduct directly and/or indirectly attributable to the Local Compliance Officer, the report must be transmitted through the Group's Central Reporting Channels in order to ensure the impartiality of the treatment of the case.

In handling reports of potentially serious violations, NTC acts with Dr. Ing. h.c. F. Porsche by virtue of a special agreement, in order to ensure that violations of the law committed and appropriately reported are investigated, remedied and sanctioned according to uniformly applicable standards.

The reports received, the related checks and analyses and all the reference documentation, will be kept for the time necessary to process the report and in any case no longer than 5 (five) years from the date of communication of the final outcome of the reporting procedure, in compliance with confidentiality obligations.

All processing of personal data is carried out in compliance with the applicable legislation on the protection of personal data. To find out more, see the section below "Information relating to the protection of personal data".

Anyone who receives a report, in any form (written or oral), must send it promptly, and in any case within 7 (seven) days of receipt, through the aforementioned channels, giving simultaneous notice of the transmission to the whistleblower (if known) and guaranteeing absolute confidentiality.

The National Anti-Corruption Authority (ANAC) has adopted an external reporting channel that can be used where one of the following conditions is met:

• the Whistleblower has already made a report using NTC's internal reporting channel (so-called "Internal Reporting") and the same has not been followed up;

• the Whistleblower has reasonable grounds to believe that, if he or she made an internal report, it would not be followed up effectively or that the same report could lead to the risk of retaliation;

• the Whistleblower has reasonable grounds to believe that the violation he intends to report may constitute an imminent or obvious danger to the public interest.

The external reporting channel guarantees, also through the use of encryption tools, the confidentiality of the identity of the Whistleblower, the person involved and the person mentioned in the report, as well as the content of the report and the related documentation.

For more information or to report using the external reporting channel set up for this purpose by ANAC, consult the institutional website at the following link: https://www.anticorruzione.it/-/whistleblowing

Information relating to the protection of personal data in the context of the Whistleblowing System is contained in the following policies: