In compliance with applicable legislation, Seanergy a Marine Interiors Company srl (hereinafter also ‘Seanergy’) has adopted a Whistleblowing procedure, which provides procedures and conditions for filing internal reports, as well as the conditions for the use of the external channel. Responsibility for managing Whistleblowing System is entrusted to the Group Internal Audit Department, hereinafter the “Whistleblowing Coordinator”, ensuring the necessary autonomy and independence, intended as impartiality, absence of interference and full operational and evaluative autonomy. Reports may be submitted at any time by employees and third parties and may concern actual or suspected violations of the Code of Ethics, the Organisational Model, the Anti-Corruption Policy, or the company procedures adopted by the Company, as well as any violations of European Union law, national and international provisions.

The adopted Whistleblowing System allows a report to be made in written or oral form through the following internal channels:

• Online Platform: submission through the platform can be made with or without registration, in written form or via voice messaging. The channel is suitable for ensuring the confidentiality of sources and information obtained, subject to legal obligations. Use the “Reports” button to access the platform.
• Postal Address:
  Fincantieri S.p.A.
  Via Genova 1, 34121 Trieste, Italy
  Seanergy a Marine Interiors Company S.r.l - Confidential Whistleblowing Coordinator
• Direct Meeting with the Whistleblowing Coordinator, at the Whistleblower’s request, through a direct meeting scheduled within a reasonable timeframe via the aforementioned channels. The report is recorded in writing and signed by the Whistleblowing Coordinator and the whistleblower or otherwise recorded.

The whistleblower must use only the whistleblowing channels indicated above, which ensure the confidentiality of their identity, that of the individuals involved and the content of the report. The online platform should be preferred because it allows the Whistleblowing Coordinator to communicate (also anonymously) with the whistleblower and enables the latter to check the status and outcome of the report at any time.

Any reports of an ambiguous nature, or not detailed, or clearly made in bad faith, or with slanderous and libelous content will not be taken into consideration. For this purpose, the reporting person is requested to consult the following procedure so as to ensure the proper and effective handling of the report: Whistleblowing procedure

The reporting system adopted is in compliance with the requirements of the Legislative Decree No. 24/2023 implementing Directive (UE) 2019/1937 regarding “the protection of individuals who report violations of European Union law and national provisions".

Safeguard rules

The Company guarantees the utmost confidentiality as far as the source and the information provided are concerned, except when legally required. Seanergy prohibits any form of retaliation (disciplinary sanctions, downgrading, suspension, lay-off) as well as any discrimination against Company employees who, in good faith, report violations of the Code of Ethics, Organizational Model, Anti-corruption Policy, the Supplier Code of Ethics or the Company procedures and legal regulations. This protection applies also to: facilitators (persons who support the whistleblower); persons in the whistleblower working environment, linked to him by a stable emotional or family relationship; colleagues having a regular and current relationship with the whistleblower; entities owned by the whistleblower or where he works, as well as to entities operating in the same working environment. These persons are clearly identified by Art. 3 of Legislative Decree 10 March 2023 No. 24.