Whistleblowing

Welcome to the digital system for the management of corporate wrongdoing reports according to EU Directive 2019/1937 transposed by Legislative Decree 10th march 2023, n. 24.

By means of this corporate compliance tool, employees or third parties of a company can report, in a confidential and protected manner, any wrongdoing encountered in the course of their work.

WHAT CAN BE REPORTED

Conduct, acts or omissions detrimental to the public interest or the integrity of the public administration or the private entity and consisting of:

administrative, accounting, civil or criminal offences;
unlawful conduct relevant under Legislative Decree 231/2001, or violations of the organisation and management models provided for therein;
offences falling within the scope of EU or national acts relating to the following areas: public procurement; financial services, products and markets and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; privacy and personal data protection and security of networks and information systems;
acts or omissions affecting the financial interests of the Union;
acts or omissions relating to the internal market;
acts or conduct that frustrate the object or purpose of the provisions of Union acts.
discriminatory acts or behaviour contrary to Gender Equality that may occur in the workplace.

WHAT CANNOT BE REPORTED

The following are excluded from the application of this regulation:

complaints, claims or requests linked to a personal interest of the reporting person or of the person lodging a complaint with the judicial authority that relate exclusively to his/her individual work or public employment relationship, or to his/her work or public employment relationship with hierarchical superiors (therefore, excluded are, for instance reports concerning labour disputes and pre-litigation phases, discrimination between colleagues, interpersonal conflicts between the reporting person and another worker or with hierarchical superiors, reports concerning data processing carried out in the context of the individual employment relationship in the absence of injury to the public interest or to the integrity of the public administration or private body);
reports of violations where they are already mandatorily regulated by the European Union or national acts indicated in Part II of the Annex to the Decree or by national acts constituting the implementation of the European Union acts indicated in Part II of the Annex to Directive (EU) 2019/1937, although not indicated in Part II of the Annex to the Decree;
Reports of national security breaches, as well as of procurement relating to defence or national security aspects, unless these aspects are covered by relevant secondary EU law.

SIGNALLING CHANNELS

internal;
external (managed by A.N.A.C.);
public dissemination (through the press, electronic media or media capable of reaching a large number of people);
report to the judicial or accounting authorities.

CHOICE OF SIGNALLING CHANNEL

Whistleblowers may use the external channel (ANAC) when:

there is no compulsory activation of the internal reporting channel within the work context, or this channel, even if compulsory, is not active or, even if activated, does not compla persona segnalante ha già effettuato una segnalazione interna e la stessa non ha avuto seguito;ly with what is required by law;
the reporting person has already made an internal report and it was not followed up;
the reporting person has reasonable grounds to believe that, if he or she were to make an internal report, the report would not be effectively followed up or that the report might lead to a risk of retaliation;
the person issuing the alert has reasonable grounds to believe that the breach may constitute an imminent or obvious danger to the public interest;

Whistleblowers may directly make a public disclosure when:

the reporting person has previously made an internal and an external report or has made an external report directly and no reply has been received within the prescribed time limits on the measures envisaged or taken to follow up the reports;
the person issuing the alert has reasonable grounds to believe that the breach may constitute an imminent or obvious danger to the public interest;
the reporting person has reasonable grounds to believe that the external report may involve a risk of retaliation or may not be effectively followed up due to the specific circumstances of the case, such as where evidence may be concealed or destroyed, or where there is a well-founded fear that the recipient of the report may be colluding with or involved in the perpetrator of the violation.

CONDITIONS FOR REPORTING

Reasonability

At the time of the report or denunciation to the judicial or accounting authorities or public disclosure, the reporting or denouncing person must have a reasonable and well-founded reason to believe that the information about the violations reported, publicly disclosed or denounced is true and falls within the scope of the legislation Modalities
Reporting or public disclosure must be made using the channels provided (internal, external and public disclosure) according to the criteria indicated). More information in relation to ANAC's competences is available by accessing the above-mentioned Authority's website (https://www.anticorruzione.it/ in the appropriate section).

PLEASE NOTE:

The ANAC has provided for sanctions of between €500 and €2,500 for whistleblowers in the event that the whistleblower is found to be criminally liable for the offences of defamation or slander.

I PROCEED WITH THE REPORT

We also inform you that the external channel managed by ANAC is available by accessing the link:

https://whistleblowing.anticorruzione.it/#/

Finally, we inform you that, in the event of an external report, this will be handled by ANAC in accordance with the "Regulation for the management of external reports and the exercise of the ANAC's sanctioning power in implementation of Legislative Decree no. 24 of 10 March 2023. Resolution No. 301 of 12 July 2023".