BG FUND MANAGEMENT LUXEMBOURG S.A. promotes and encourages the diffusion of a corporate culture of legality characterized by correct behaviour and guarantees effective and efficient means aimed at preventing, managing and possibly reporting any irregularities or violations of the rules governing company activity, through secure and confidential channels.

The Company encourages the reporting of any behaviour which, in good faith, is considered illegitimate, to its internal contacts (its Manager, the HR Function, contractual contacts,...).

It is also possible to submit a report via the following reporting channels established under the Whistleblowing Policy (the “Policy”).

• Dedicated IT platform, via web or by phone (+352 20 33 43 18);
• E-mail: whistleblowing@bgfml.lu;
• Confidential and personal written communication sent to the “Compliance Officer” c/o BG Fund Management Luxembourg, 14, Allée Marconi, L-2120 Luxembourg.

Note: reports can be submitted in Italian, English, French, German and Luxembourgish.

Such channels:

• are available to employees of the Company, external collaborators / freelancers / consultants / trainees who work for the Company and people from Governing Bodies and control functions at the Company itself;
• are monitored by the Compliance Officer who, through them, can also be asked for a meeting and or further information.

The reporting channels are not aimed at managing irrelevant communications for which dedicated contact points are established (e.g. complaints and/or requests from third parties of a commercial nature).

The reports must concern negligent, illicit, irregular or incorrect circumstances and conducts - in violation of the law, the Internal Code of Conduct (drawn up in line with the principles of the Generali Group Code of Conduct) or any other internal regulations - for which there is reasonable suspicion or of which someone has become aware in the performance of his duties, for example relating to: administrative, accounting and tax obligations irregularities; violation of anti-money laundering and financial combating terrorism rules; insider trading and/or market manipulation; irregularities in the provision of services and investment activities; privacy violations; bullying and harassment; corruption; fraud.

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.

Whistleblowers in good faith are guaranteed and protected against any form of retaliation, discrimination, or other unfair consequences of reporting, regardless of the subjects involved.

For further details, please refer to the “Whistleblowing Policy”.

In cases where:

• an internal report has already been made and it has not been followed up;
• the whistleblower 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 the risk of retaliation;
• the whistleblower has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest,

the competent body for reporting is the Luxembourg Ministry of Justice (see Whistleblower - Ministry of Justice // The Luxembourg Government (gouvernement.lu)).