WHISTLEBLOWING

Whistleblowing (literally “blowing the whistle”), introduced in Italy by Law No. 190/2012, aims to protect the public and general interest, legality, and ethics in administrative actions.

Legislative Decree No. 24/2023, implementing EU Directive No. 2019/1937, governs the protection of individuals who report violations of national or EU laws that harm the public interest or the integrity of public administration or private entities, which they have become aware of in a public or private work context.

WHO can report

The following individuals may submit reports:

1. employees of the company, including those on probation or retired;
2. self-employed workers, collaborators, freelancers, interns, volunteers;
3. workers or collaborators who perform their activity at the company, who provide goods or services or carry out work for third parties;
4. persons with administrative, management, control, supervisory, or representative roles (e.g., members of the Evaluation Unit, Board of Auditors, Board of Statutory Auditors, etc.).

WHAT can be reported

1. Behaviors, acts, or omissions that harm the public interest, the integrity of Public Administration, or the Company itself, including administrative, accounting, civil, or criminal offenses as detailed in Article 2 of Legislative Decree No. 24 of March 10, 2023.
2. Complaints, claims, or requests related to personal interests, even if reported to judicial or accounting authorities, concerning only individual employment or public service relationships, or those involving hierarchical superiors, will not be considered.
3. The report must be detailed, concern verifiable facts known directly by the whistleblower and not reported by others, and include all information and data needed to unequivocally identify the authors of the violation.

INTERNAL REPORTING CHANNEL via digital platform

To submit a report, the following steps must be followed:

1. download the browser from the following address: https://www.torproject.org/it/download/
2. enter the following link in the Tor browser search bar: https://rbtmcjkcbnl7nzlvnghparn6vfym4mukf2f4mtmvcmd6blk3eubevfid.onion
3. fill out the form shown on screen after selecting “submit a report”
4. save the report receipt (16-digit numeric code) to track progress or provide additional information later

The report ensures the confidentiality of the identity of the whistleblower, the person involved, and any person mentioned in the report, as well as of the report’s content and related documentation.

The information in the report will be accessible only to the appointed case handler and will be processed in compliance with data protection regulations.

PROHIBITION OF RETALIATION

Persons submitting a report may not suffer any retaliation (Art. 17, paragraph 4, Legislative Decree 24/2023).

PROCESSING OF PERSONAL DATA

It is necessary to read the dedicated privacy notice available on the website.