Whistleblowing

Reporting violations

Directive 2019/1937/EU – Legislative Decree 24/2023

The term whistleblowing, in the corporate sphere, refers to the spontaneous disclosure by an employee or an interested third party, known as a “whistleblower,” of a violation or wrongdoing committed within the entity, of which he or she has become aware in the course of performing his or her job.

Violations are behaviors, acts or omissions thatharm the public interest or integrity of the Public Administration or Private Entity.

WHAT IS NOT RELEVANT TO REPORT ?

Challenges, claims, or demands do not fall within the scope of Legislative Decree 24/2023:

• related to an interest of a personal nature of the reporter.
• pertaining exclusively to their individual labor relations.
• inherent in their working relationships with hierarchically subordinate figures.

In addition, it is not relevant to report violations that are already regulated by the acts of the European Union (Part II, Annex Dir. 2019/1937/EU) or national regulations (Part II, Annex D.Lgs. 24/23) and related to financial services, products and markets, prevention of money laundering and terrorist financing (…).

HOW SHOULD THE REPORTS BE ?

Reports of violations must be circumstantiated and consist of specific and detailed information, i.e., the narration by the reporter, of facts, events or circumstances of the alleged violation, must be made with a sufficient degree of detail to enable the “Reporting Manager” to identify useful or decisive elements for the purpose of verifying the merits of the report.

The Reporting Manager ensures the confidentiality of the reporter and the data and information shared.

INTERNAL REPORTING CHANNEL TOOLS

Reports can be sent through the following means: