RECALL MANAGEMENT POLICY

PRODUCT RECALLS, WITHDRAWALS, AND SAFETY INCIDENT MANAGEMENT POLICY

Last updated: [publication date]

1. PURPOSE

This Policy governs the general principles and procedures adopted by ZEROTRACCE for managing any product safety issues, incidents, withdrawals, recalls, and other corrective actions that may be necessary.

This Policy complements:

- the Product Safety Policy;
- the Terms and Conditions of Sale;
- the Legal Guarantee of Conformity;
- the Returns and Refunds Policy;
- the Complaint and Reporting Management Policy;
- safety information published on individual product pages.

2. GENERAL SAFETY PRINCIPLE

ZEROTRACCE considers product safety a priority in its sales operations.

Should information emerge that may indicate a potential risk associated with a product, the report may be subject to evaluation to determine:

- the product concerned;
- the nature of the issue;
- the possible extent of the issue;
- the level of risk;
- any measures that may be necessary.

3. PRODUCTS CONCERNED

This Policy may apply to all products marketed through the ZEROTRACCE website, including, by way of example:

- Filtering Shower Head;
- Filtering Faucet;
- Replacement Filters;
- Complete Bathroom Kit;
- Family Kit;
- Complete Home Kit;
- any other products marketed subsequently.

4. REPORTING A POTENTIAL RISK

A customer who believes that a product presents a potential safety risk may send a report to:

sirius.amerion@gmail.com

The report should indicate, when available:

- order number;
- product name;
- description of the issue;
- date of the event;
- photographs;
- videos;
- identifiers present on the product or packaging;
- description of the circumstances in which the issue occurred.

5. DISCONTINUATION OF USE

If the customer reasonably believes that the product may present a safety risk, it is advisable to discontinue its use until the situation has been assessed.

When necessary, ZEROTRACCE may provide further instructions regarding the management of the product.

6. INCIDENT

For the purposes of this Policy, an "incident" means an event that may be linked to the use of a product and that requires a safety assessment.

Each report is evaluated based on the specific circumstances and available information.

7. INFORMATION GATHERING

To assess a potential incident or safety issue, relevant information may be gathered, such as:

- product identification;
- order number;
- date of purchase;
- date of delivery;
- description of the event;
- photographs;
- videos;
- available information on use;
- information regarding packaging;
- any information relating to the batch or other identifiers.

The information reasonably necessary for managing the case will be requested and processed.

8. PRODUCT IDENTIFICATION

When possible, the evaluation may include checking the identification details available on the product, on the packaging, on the label, or in the accompanying documentation.

The customer is requested not to remove or alter such identifiers before having received any instructions from customer support.

9. RISK ASSESSMENT

When a report may concern product safety, the situation may be subjected to an assessment proportionate to the nature and severity of the information received.

The assessment may consider, among other elements:

- nature of the issue;
- possible severity of the consequences;
- frequency of reports;
- product and configuration involved;
- method of use;
- available technical documentation;
- information from the supply chain;
- any previous reports.

10. INVOLVEMENT OF RELEVANT OPERATORS

When necessary, managing an issue may require the involvement of the relevant economic operators in the supply chain.

Depending on the case, the manufacturer, the responsible person in the European Union, the carrier, or other parties with a relevant role may be involved.

The involvement of these parties does not alter the consumer's rights with respect to the seller.

11. PREVENTIVE MEASURES

If information emerges that requires further verification, preventive measures proportionate to the situation may be adopted.

Such measures may include, when appropriate:

- temporary suspension of sale;
- temporary suspension of distribution;
- request for further information;
- verification of documentation;
- verification of the products concerned;
- communication to affected customers.

12. PRODUCT WITHDRAWAL

"Withdrawal" may refer to measures aimed at preventing a product in the distribution chain from continuing to be made available, when required by the situation and applicable regulations.

The specific methods of withdrawal depend on the nature of the identified issue.

13. PRODUCT RECALL

"Recall" may refer to measures aimed at achieving the return of a product already made available to consumers when necessary to address a safety risk.

Any recall is carried out according to the procedures and obligations applicable to the specific case.

14. COMMUNICATION OF A RECALL

When it is necessary to proceed with a recall, communications to affected customers may contain, as needed:

- product identification;
- description of the issue;
- potential risk identified;
- indications regarding the suspension of use;
- instructions for return;
- instructions for obtaining assistance;
- any other necessary information.

15. COMMUNICATION CHANNELS

Communications regarding a recall or safety issue may be carried out through one or more appropriate channels, including:

- email;
- individual communications to affected buyers;
- website;
- product safety dedicated page;
- other channels deemed appropriate depending on the situation.

16. AFFECTED CUSTOMERS

When technically and legally possible, communications may be addressed directly to customers identified as affected based on order data and available information.

The method of communication depends on the nature, extent, and urgency of the issue.

17. CUSTOMER INSTRUCTIONS

When an issue is identified that requires action by the customer, the latter will receive, where necessary, instructions regarding how to manage the product.

The customer must follow the safety instructions received and must not independently proceed with modifications or interventions that may increase the risk.

18. RETURN OF A RECALLED PRODUCT

When the return of a recalled product is requested, ZEROTRACCE will communicate the applicable operational procedures.

The customer must not ship the product to an address other than the one indicated by support for the specific procedure.

19. COSTS RELATED TO A RECALL

When a recall procedure or other corrective action involves the return of the product, the details regarding costs will be communicated to the customer based on the specific situation and applicable regulations.

20. REMEDY

Depending on the nature of the issue and applicable provisions, the remedy may include, where provided:

- replacement;
- repair;
- refund;
- other appropriate corrective measure;
- other solution provided for by applicable law.

The specific solution is determined based on the circumstances of the case.

21. DIFFERENCE BETWEEN RECALL AND ORDINARY RETURN

A safety-related recall is distinct from the normal exercise of the right of withdrawal or the commercial return procedure.

Safety procedures may involve specific instructions that differ from normal return procedures.

22. DIFFERENCE BETWEEN RECALL AND LEGAL GUARANTEE

A safety issue may be distinct from a simple dispute regarding product conformity.

The Legal Guarantee of Conformity continues to apply according to current legislation and the relative policy published on the site.

23. UPDATING INFORMATION

When verification changes the information initially available, ZEROTRACCE may update:

- product information;
- warnings;
- instructions;
- FAQs;
- safety information;
- customer communications.

24. CORRECTIVE ACTIONS

Any corrective actions will be proportionate to the nature of the issue and may be adopted according to applicable law.

Depending on the circumstances, they may include:

- correction of information;
- update of instructions;
- modification of warnings;
- suspension of sales;
- withdrawal;
- recall;
- replacement;
- repair;
- refund;
- other necessary measures.

25. COOPERATION WITH AUTHORITIES

When required by applicable law or the circumstances of the case, relevant information may be communicated to the competent authorities.

Cooperation may involve, among other things:

- product identification;
- nature of the risk;
- number of products concerned;
- corrective measures adopted;
- distribution information;
- other requested information.

26. DOCUMENTATION

Information regarding incidents, safety reports, and corrective actions may be documented and kept for the period necessary for managing the situation and any applicable legal obligations.

27. TRACEABILITY

When available, order documentation may be used to identify:

- the purchased product;
- the date of the order;
- the date of delivery;
- the customer concerned;
- communications made;
- any actions taken.

28. PROTECTION OF PERSONAL DATA

Personal data processed in the context of incidents, recalls, or other safety procedures are managed in compliance with applicable personal data protection laws.

For further information, please refer to the Privacy Policy published on the site.

29. CUSTOMER REPORTS

Every customer is invited to promptly report any issue that may reasonably concern the safety of a product.

A prompt report can facilitate the analysis of the issue and the adoption of any necessary measures.

30. CONTACTS FOR PRODUCT SAFETY

For reports regarding product safety:

Email:
sirius.amerion@gmail.com

Recommended subject line:
PRODUCT SAFETY REPORT – [ORDER NUMBER]

31. INFORMATION TO BE INDICATED IN THE REPORT

When available, the customer should indicate:

- first and last name;
- order number;
- product name;
- date of purchase;
- description of the event;
- date of the event;
- photographs;
- videos;
- product identifiers;
- any other directly relevant information.

32. EMERGENCIES

In the presence of a situation involving an immediate danger to health or safety, the customer must take appropriate emergency measures and contact the competent emergency services when necessary.

The ZEROTRACCE customer service does not replace emergency services.

33. LIMITS OF THIS POLICY

This Policy describes general reporting management procedures and does not constitute a guarantee that a specific report will necessarily result in a recall or withdrawal.

Each situation is evaluated based on the available information and applicable law.

34. CONSUMER RIGHTS

This Policy does not limit the mandatory rights granted to consumers by applicable law.

In case of conflict between this Policy and a mandatory provision of law, the applicable provision of law shall prevail.

35. UPDATES

ZEROTRACCE may modify this Policy when necessary to reflect:

- regulatory changes;
- product changes;
- changes in safety procedures;
- supply chain changes;
- new technical information;
- new recall or withdrawal procedures.

The version published on the site constitutes the updated version of the Policy.

36. SELLER IDENTITY

Amerion Group LLC

30 N Gould St #36862
Sheridan, WY 82801
USA

EIN: 32-0818127

Customer service:
sirius.amerion@gmail.com

37. RELATIONSHIP WITH OTHER POLICIES

This Policy must be read in conjunction with other information published on the site, including:

- Terms and Conditions of Sale;
- Product Safety Policy;
- Complaint and Reporting Management Policy;
- Legal Guarantee of Conformity;
- Returns and Refunds Policy;
- Shipping and Delivery;
- Legal Information on the Product;
- Privacy Policy.

38. UPDATE DATE

Last updated: [publication date]