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Whistleblowing Reports

In implementation of the provisions of Legislative Decree 24/2023 (decree on "whistleblowing"), the Company has equipped itself with a system for the submission and management of internal reports.

The operation of the system in question is governed by a corporate organizational act, defined as a whistleblowing policy and to the contents of which reference is made. The user is therefore invited to carefully read the document, regulating in particular the conditions and methods of use of the reporting tool - which if it does not comply with the specified requirements cannot be managed in accordance with the legislation in question - as well as the protections and sanctions provided.

By way of example, it should be noted that the offenses of interest for possible reporting include those related to public procurement (by way of example: irregularities in the manner of awarding funds, participation in public tenders), product safety and compliance (e.g. in labeling),environmental protection (wrongdoing in environmental matters, e.g., in waste management), food and feed safety, animal health and welfare, public health (e.g., in the quality and safety of medicinal products and medical devices), consumer protection (e.g., unfair business practices, violation of consumer rights, unfair competition), personal data protection, and security of networks and information systems.

Therefore, by way of example, reports related to a personal interest of the whistleblower, pertaining to his or her own individual labor relations, or inherent to labor relations with hierarchically subordinate figures, as well as those related to commercial issues (products, services, etc.)do not fall within the scope of this discussion.

Reports must be well-founded in order not to incur criminal, civil and disciplinary liability, a situation that can be found in the case of slanderous or defamatory reporting.

The following persons are authorized to make reports under these regulations:

  • the Company's employees;
  • the self-employed workers and collaborators of the Company;
  • the workers or collaborators of suppliers;
  • the Company's freelancers and consultants;
  • the volunteers and trainees employed by the Company;
  • persons with functions of administration, management, control, supervision or representation within the Company.

The report may be made either orally or in writing.

In the latter case, the internal reporting channel activated by the Company provides for the use of aspecial IT platform that makes use of secure protocols and encryption tools that enable the protection of personal data and information, including those contained in any attachments to the report.

This platform can be accessed from the following link:

Regarding how to use the aforementioned program, please refer to the instructions contained in the aforementioned whistleblowing policy.

In particular, please note that upon the outcome of the report , a unique code (key-code) will be generated to the reporter, which must be kept by the reporter in order to be able to interact with the platform and know the outcome of the report.

Reports will be handled by an external party, called the report manager, duly appointed and authorized by the Company.

The report will be handled in the following stages:

  1. submission of the report by the reporter;
  2. notice to the reporter of receipt of the report (within 7 days);
  3. assessment of the admissibility of the report under the whistleblowing regulations;
  4. assessment of the existence of the requirements proper to the report;
  5. possible request for additions to the report;
  6. internal investigation of the reported facts;
  7. response to the report (within 3 months from the notice of receipt of the report).

The Company guarantees whistleblowers, so-called facilitators and other persons mentioned in Article 3 of the Decree a system of protection that finds its expression in particular in the protection of the confidentiality of the data of such persons and the content of the report, in the protection of such persons against possible retaliation.

However, the reader of this informative documentis invited to the complete vision of the company protocol called "WHISTLEBLOWING POLICY Procedure for the submission and management of internal reports and related guarantees" where all the features of the whistleblowing system adopted by the Company and the instructions for its proper use are identified in detail.