PIRELLI TIRE NORTH AMERICA
WHISTLEBLOWING POLICY – COMPLAINT PROCEDURE

GOAL
Pirelli Tire North America (“Pirelli”) provides its shareholders, employees, suppliers, customers, all its stakeholders, and the general public with a channel to report any acts or omissions adopted by any party within Pirelli, in its relations with Pirelli or on its behalf, that constitute or may constitute a violation or inducement to violate laws and/or regulations, the principles enshrined in the Pirelli Values and Ethical Code (see link below), principles of internal control, company policies, rules and procedures or that can either directly or indirectly give rise to economic, financial or reputational damage to Pirelli.

Link: http://www.pirelli.com/corporate/en/sustainability/sust_develop/policies/values/default.html
This Whistleblowing/Complaint procedure (“Procedure”) shall not prevent compliance with any statutory obligations, particularly regarding mandatory reports to legal or regulatory authorities, as well as in regard to the processing of personal data and privacy protection envisaged by the local law, rule or legislation.

CONTENT OF REPORTS
Reports can be made about directors, management and employees of Pirelli and, in general, everyone who works for or on behalf of Pirelli inside and outside the US or has business relationships with Pirelli, including independent auditing companies, partners, customers, suppliers, consultants, contractors, institutions and public entities.

Reports can also be made anonymously, all reports will be taken seriously. Pirelli however recommends that you provide as much information as possible, contact information, in order to support an adequate investigation.

Reports should contain all useful and appropriate elements required to investigate the allegations.

MAKING A REPORT
Reports may be made by phone or online.

  • By phone: call the Concerns Hotline at 1-844-498-1268. The anonymous hotline is run by a third party and is answered 24 hours a day, 7 days a week.
  • Online: report the possible violation on the Pirelli Concerns Website (https://pirellinaconcerns.tnwreports.com). Reporting online is anonymous and run by a third party. The website is available 24 hours a day, 7 days a week.
PRIVACY PROTECTION AND NON RETALIATION

The hotline is designed to protect the anonymity of whistleblowers. Pirelli reserves the right to adopt all appropriate actions against whosoever engages in acts of reprisal in respect of whistleblowers within the scope of this Policy.

Pirelli will not tolerate threats or reprisals of any kind against anyone who in good faith makes a report or assists with the investigations. Anyone who believes he/she is being retaliated against should immediately contact Pirelli Tire LLC Human Resources and make a report directly to the third party hotline or website.

Disciplinary action may be adopted in the event of abuse of this Procedure (reports made in bad faith and/or intentionally filed false reports).

 

INVESTIGATION ON CONTENT OF REPORTS

The Internal Audit Department of Pirelli & C. S.p.A. will be informed of all complaints received.

The actions taken to ascertain the veracity of the circumstances represented in reports will be performed in compliance with principles of impartiality and confidentiality, taking all actions deemed to be appropriate and involving the designated company offices.

In the event of proven validity of the report, Pirelli Tire LLC will adopt appropriate disciplinary measures and actions, including those to protect the company itself and the Pirelli Group from instances like this happening in the future.

If for any reason an employee of Pirelli Tire LLC receives a report directly, he or she has the obligation to immediately forward the report to the third-party hotline or website.

The Whistleblower will be notified, if he/she requests, upon completion of the investigation.