The Company has adopted a system for the management of whistleblowing reports in compliance with the regulatory requirements on Whistleblowing (Legislative Decree No. 24/2023).
Personnel and Third Parties (as defined in the extract of the attached Policy) may submit Reports in written or oral form concerning information on the violations that the Whistleblower became aware of within the context of the work.
For the purposes of this Policy, Reporting covers information, including reasonable suspicions, concerning violations committed or which, on the basis of concrete elements, could be committed in the organisation with which the whistleblower has a legal relationship, as well as conduct aimed at concealing such violations.
More specifically, the whistleblower may report conduct, acts or omissions that result in harm to the public interest or the integrity of the public administration or private entity and which consist of:
The Company ensures the protection of the Whistleblower in good faith against any act, action, retaliatory behaviour directly or indirectly connected to the Report.
In the event of unfounded Reports and/or submitted in bad faith, the Company reserves the right to act in defence of its own interests and to protect the damaged parties.
Any complaints and/or claims relating to the provision of services or products provided to Personnel and Third Parties (as defined in the extract of the attached Policy) of the Company are not subject to Whistleblowing.
The Company has prepared the following internal channels to receive the Reports:
A direct and confidential meeting with the Reporting Manager can also be organised by conveying the request through one of the channels mentioned above.
All channels ensure the confidentiality of the identity of the Whistleblower, the Reported Party, the Facilitator, the person in any case mentioned in the Report, as well as the content of the Report and the related documentation.
The eWhistle platform is the preferred channel for the transmission and management of Reports.
The Whistleblower may file an external report to the ANAC if, at the time of its submission, one of the following conditions applies:
Therefore, the choice of the reporting channel is not left to the Whistleblower since priority is given to the use of the internal channel and it is only possible to make an external report if one of the above conditions has been met.
External reports may also be filed in written form via the ANAC IT platform or verbally via telephone lines or voice messaging systems, or, at the request of the whistleblower, by means of a face-to-face meeting set within a reasonable period of time.
The Whistleblower may also resort to public disclosure if:
For more information on how to submit a Report, please refer to the following document:
For more information on how to manage Reports, please consult the extract of the Company Policy:
Please read the Information notice on the protection of personal data pursuant to Articles 13 and 14 of European Regulation 2016/679