We are committed to creating a culture of openness, transparency, integrity and accountability in which our workforce and other stakeholders, such as customers and suppliers, feel comfortable reporting violations without fear of retaliation.
We encourage people to use our internal reporting channel to inform us of possible violations. This enables us to identify and address them as soon as possible, take appropriate action, prevent further misconduct, and limit potential financial, reputational, environmental, human, and other harmful impacts.
We are committed to ensuring that reported violations are handled diligently and confidentially, applying the principles of trust, impartiality and protection, and providing appropriate feedback throughout the process. In this regard, we are committed to continually improving our reporting management system.
This whistleblowing policy is not a substitute for managers taking responsibility in their workplace and does not prevent an individual from reporting to the appropriate authorities.
To whom does this policy apply?
This policy applies to whistleblowers. Whistleblowers are those who have acquired information about violations in the workplace.
This includes, but is not limited to, our current and former employees, self-employed workers, shareholders, and persons belonging to the management or supervisory body of our company, including their non-executive members, as well as volunteers, paid or unpaid trainees , clients, principals, and all persons working under the supervision and direction of our partners, contractors, subcontractors, and suppliers.
This policy also applies to whistleblowers whose employment relationship has yet to commence in cases where information about violations has been acquired during the recruitment process or other pre-contract negotiations.
The protections provided by this policy are also afforded to individuals who assist the reporter in the reporting process (facilitators), third parties who have ties to the reporter (colleagues or relatives) and who may face retaliation in a work setting, and legal entities that the reporter the reporter owns, works for, or is otherwise connected to in a work setting.
What to report?
The internal reporting channel is intended for reports where a whistleblower has at least reasonable suspicion about actual or potential violations that have occurred, are currently occurring, or are very likely to occur, and about attempts to conceal such violations.
A violation is any act or omission that is illegal and related to our company, or that frustrates the object or purpose of legislation, our policies and/or internal regulations. A violation may include, but is not limited to, the following:
How to report?
Authorized personnel (see below) are available to provide support or advice on the company’s whistleblowing process.
Reporting Channels
Reports can be submitted using the company’s online reporting solution “Trusty” available at https:\\gruppostorti.trusty.report.
It is desirable for the reporter to use, in the first instance, the internal reporting channel set up by the Company, however, the latter, in certain cases, has the option to apply directly to ANAC (National Anti-Corruption Authority – www.anticorruzione.it). Other forms of external reporting provided for, may be represented by public disclosure and/or reporting to the judicial or accounting authorities.
The conditions that warrant external reporting to ANAC are as follows:
The conditions warranting public disclosure are as follows:
A report should include as much detail as possible about the who, what, where, when, how, and why in relation to the reported violation, as well as any supporting evidence. Any other information on how the company might best proceed to process the reported violation is welcome.
Whistleblowers can send reports anonymously or can choose to disclose their identity.
The “Trusty” platform enables anonymous two-way communication even if a whistleblower chooses to report a breach without revealing his or her identity.
Whistleblowers are encouraged to identify themselves. This allows for more productive and efficient processing of their reports and their protection against retaliation.
The identity of whistleblowers, as well as any other information from which their identity may be directly or indirectly inferred, shall not be disclosed to anyone other than the personnel authorized and competent to receive and follow up on reports, without the express consent of the whistleblowers. Notwithstanding the preceding provision, the company is required to disclose the identity of the whistleblower when required by law, informing the whistleblower prior to such disclosure, unless such information would jeopardize the relevant investigation or prosecution.
Any unauthorized attempts to identify a reporter or a person of interest are not permitted and will be disciplined.
By whom and how are reports processed?
Authorized personnel
The company’s internal reporting channel is managed by Dr. Chiara Giacopini, who is authorized to receive and follow up on reports (hereafter referred to as authorized personnel).
Authorized personnel have direct, unrestricted, and confidential access to the Company’s management to which they report directly on the progress of the whistleblower management system. Authorized personnel shall have direct and unrestricted access to appropriate resources necessary to ensure the impartiality, integrity, and transparency of the whistleblower management system and its processes.
Report Processing
Report processing is carried out in the following stages, depending on the content of the report and its nature:
The company aims to process reports in a timely manner. Circumstances such as the complexity of the reported violation, competing priorities, and other compelling reasons may require an extended period for the completion of report processing.
The company treats reports confidentially, impartially, and without bias or prejudice against the reporter or any other person involved in or witness to the reported violation.
The persons concerned, that is, the persons named in the reports, enjoy the presumption of innocence. Their respective reports may be disclosed to them at the appropriate time. Any investigation must be conducted in a manner that preserves confidentiality to the extent possible and appropriate to ensure that the persons concerned are not exposed to reputational damage (information is shared on a strict need-to-know basis).
Communication with Whistleblowers
After submitting a report, the whistleblower will receive an acknowledgement of receipt immediately and no later than seven days after receiving it.
Confirmation of receipt is sent to the email address provided by the reporter during the online reporting process on the “Trusty” reporting platform. Confirmation of receipt of the report is also provided in the reporter’s inbox accessible on the “Trusty” platform using the login credentials that are provided to the reporter at the end of the report submission process. These are also provided to anonymous reporters.
Authorized personnel maintain communication with the reporter and, where necessary, request additional information or evidence and provide feedback to the reporter. The above communication is done through the reporter’s mailbox on the “Trusty” platform, or through other communication channels agreed upon with the reporter.
Feedback to the reporter is provided no later than 3 months after the submission of the report. The feedback shall include information on the action planned or taken as follow-up and the reasons for such follow-up. Feedback may be limited to avoid compromising possible investigations or other legal proceedings, as well as because of legal restrictions on what can be reported about follow-up and results. In such a case and where possible, the reporter will be notified of the reasons for the limited communication of feedback.
The company may decide to recognize and give recognition to the whistleblower for reporting a violation, subject to the whistleblower’s consent (including, but not limited to, expressing gratitude and public commendation from top management).
What is retaliation and how are whistleblowers protected against it?
Prohibition of Retaliation
Retaliation is defined as any threatened, proposed or actual, direct or indirect act or omission that occurs in a work setting, is motivated by internal or external reporting or public disclosure, and causes or is likely to cause undue harm to the reporter.
Retaliation may include, but is not limited to, the following:
The company has a zero-tolerance policy toward retaliation. Any form of retaliation, including threats and attempts to retaliate, is prohibited and must be reported immediately. Such reports can be submitted using the company’s internal reporting channel.
Anyone involved in retaliation could face serious internal and potentially external consequences under applicable laws or regulations. If the company identifies anyone involved in retaliation, these individuals will be subject to disciplinary action, which could include dismissal.
Action to deal with a violation, wrongdoing, performance, or management by the whistleblower, unrelated to the whistleblower’s role in the complaint, is not considered retaliation.
Protection Against Retaliation
The company shall take all reasonable steps to protect whistleblowers from retaliation.
If it is determined that retaliation is occurring or has occurred, the company shall take reasonable steps to stop and address such conduct and support the whistleblower. If a remedy is necessary, the company shall, to the greatest extent possible, restore the whistleblower to a situation that he or she would have been in had he or she not suffered retaliation. For example:
Subsequent to reporting, authorized personnel conduct a risk assessment of the risk of retaliation against the reporter. Depending on the likely sources of harm identified through the risk assessment, the to prevent such retaliation or contain retaliatory behavior identified to prevent further harm, for example:
Authorized personnel monitor and review risks at various points in the process, such as when the decision to investigate is made, during the investigation of the report, and once the outcome of an investigation is known, after the case has been closed.
The protections under this policy apply to the whistleblower even if the reported violation is unsubstantiated, if the whistleblower had reasonable grounds to believe that the information about the reported violation was true at the time of reporting. In addition, whistleblowers who have reported or publicly disclosed information about violations anonymously, but who are later identified and suffer retaliation, will be entitled to the protection provided by this policy.
Anyone who knowingly makes false reports will be subject to disciplinary and/or other legal action, which may include dismissal.
How long are reports kept for?
If the reported violation is not substantiated by authorized personnel and the relevant data is not requested by the company for any further proceedings, the report and all information collected related to the report and its processing will be permanently deleted within 6 months after the case is closed.
If the reported violation is substantiated, the report and all information collected in connection with the report and its processing will be retained for as long as necessary for the assertion, exercise, or defense of the respective legal claims.
