WHISTLEBLOWING

HOW TO REPORT ILLEGAL ACTIVITIES

Online whistleblowing channel

The online whistleblowing channel has been activated in compliance with Legislative Decree No. 24 of 10 March 2023, to protect individuals who wish to report breaches of European Union law and national regulations (illegal activities) of which they have become aware within the company, allowing them to do so completely anonymously without fear of consequences or retaliation.

Through encryption tools, the platform ensures the confidentiality of the whistleblower’s identity, of all parties mentioned in the report, of the content of the reports and of the related documentation:


• reports are submitted by completing a questionnaire and may also be sent anonymously;

• reports are received by the person responsible for managing reports and are handled in a way that ensures, from a technological perspective, the confidentiality of both the whistleblower and the report;

• the platform enables dialogue, including anonymously, between the whistleblower and the person responsible for whistleblowing for requests for clarification or further information, without the need to provide personal contact details;

• reports can be submitted from any digital device (PC, tablet, smartphone), both from within and outside the organisation. Confidentiality is guaranteed at all times.

What can be reported:
  1. Administrative, accounting, civil or criminal offences
  2. Conduct relevant under Legislative Decree 231/01 (administrative liability for offences) or violations of organisational model requirements
  3. Offences falling within the scope of EU or national legislation (public procurement; services, financial products and markets; prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety; animal health and welfare; public health; consumer protection; protection of privacy and personal data and security of network and information systems)
  4. Acts or omissions affecting the financial interests of the EU, as protected under Article 325 TFEU
  5. Acts or omissions relating to the internal market, as referred to in Article 26(2) TFEU, including breaches of EU rules on competition and State aid, as well as corporate taxation
  6. Acts or conduct that undermine the purpose or objectives of the provisions set out in EU acts in the areas referred to in points 3), 4) and 5)
What cannot be reported:
  1. Mere suspicions
  2. Personal complaints or individual demands
  3. Claims relating to one’s own employment relationship or collaboration with the Company
  4. Disputes, claims or requests related to a personal interest of the reporting person or of a person who has filed a report with judicial or accounting authorities, which concern exclusively their individual employment relationships, or matters relating to their employment or public service relationships with hierarchically superior figures
  5. Reports of violations already mandatorily regulated by European Union or national legislation
  6. Reports concerning national security matters, as well as procurement relating to defence or national security, unless such aspects fall within the relevant derived EU law

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