WHISTLEBLOWING
We believe that reporting is always the right thing to do to help identify behaviors that may harm Group companies, their people, business partners and the environment.
We constantly work to promptly identify potential risks and we ensure appropriate follow-up on reports of possible breaches.
In this regard, by adopting the provisions of the “whistleblowing” Italian Legislative Decree (No. 24 of 10 March 2023), we have implemented a system for handling internal reports that is available to employees, collaborators and all the other stakeholders.
WHAT TO REPORT
Reports through whistleblowing channels may concern (including but not limited to):
- Health, safety and environmental rules and regulations and labour law
- Corruption or concussion
- Money laundering
- Antitrust law
- Fraud
- Conflicts of interest
- Privacy
- Disclosure of confidential information
- Code of Ethics and/or Code of Conduct
- Human rights
- Unethical or unprofessional business conducts
- Misuse of company resources
- Non-compliance with Group regulations and procedures
Reports must be substantiated and they may not concern complaints relating to business relations with the Company, nor disputes, claims or requests of a personal nature or relating exclusively to their individual relationships or concerning their employment relationships with hierarchically superior figures.
HOW TO REPORT
A report can be made through the following channels:
- Web platform
by using the link available within the box “Submit a Report”.
by writing to the dedicated e-mail addresses listed, for each Company, in Annex 1 of the “Group Guidelines” available within the box “Documentation“.
NOTE: For greater confidentiality, it is recommended to specify “CONFIDENTIAL” in the e-mail subject and to include the text of the report within an attachment.
- In-person meeting
by sending your request by e-mail to the dedicated addresses listed, for each Company, in Annex 1 of the “Group Guidelines” available within the box “Documentation“. All necessary instructions will be provided in the reply.
WHO MANAGES THE REPORTING CHANNELS
Unione Fiduciaria S.p.A. is an independent third party, who provides the web platform, on an external domain, where reports are entered and stored, ensuring proper protection and confidentiality.
Responsible for the management of the internal reporting channels (Reporting Officers) are the Company’s Supervisory Body and the Group Compliance Officer.
HOW IT WORKS
Through one of the abovementioned channels, the whistleblower transmits an information, even anonymously, to the Reporting Officers.
The Reporting Officers, in accordance with the methods and schedules required by the standard and by the Company Guideline, start a process consisting of the following steps:
- Take over: the report is received, appropriately recorded and coded. Specific feedback is provided.
- Preliminary analysis: the report is analyzed and evaluated in terms of admissibility and, if necessary, further elements are requested, always respecting anonymity.
- Investigation: if the report is deemed admissible, specific analyses are launched and the appropriate insight tools are activated. If necessary, and always respecting anonymity, further elements may be requested.
- Closure/outcome: at the end of the investigation, the findings are reported to the whistleblower, in written form.
PROTECTION
Protection of the reported person
During the investigation process, the reported person will always have guaranteed their right to defense for the facts ascribed to them. Reports made with the aim of damaging or defaming the reported person will result in action being taken against the whistleblower based on the measures provided for in the company disciplinary system and in the evaluation of the possibility of taking appropriate legal action.
Whistleblower’s protection
The Company is committed to protect those who have made a report in good faith from any form of intimidation and retaliation. Access to the web platform is managed in no-log mode, in order to prevent the identification of the whistleblower who intends to remain anonymous.
DOCUMENTATION
All supporting documentation, including instructions for using the Web Platform, is available within the box “Documents” .
