Whistleblowing – User Information
In accordance with the provisions of Legislative Decree 24/2023, Carlo Salvi S.p.A. (hereinafter also "Carlo Salvi" or "the Company") has activated its whistleblowing reporting channels.
WHO CAN REPORT?
They can make reports that will be handled in accordance with Legislative Decree 24/23:
- workers with part-time, intermittent, fixed-term, temporary, apprenticeship and ancillary employment contracts;
- workers performing occasional services;
- self-employed workers who work for the Company;
- freelancers and consultants working for the Company;
- volunteers and trainees, paid or unpaid, who work for the company;
- the Company's suppliers of goods and services;
- persons who, also de facto, hold functions of administration, management, control, supervision or representation of the Company.
WHAT CAN BE REPORTED?
Information on violations of national or European Union law, which harm the public interest or the integrity of the Company, of which the whistleblower has become aware in the course of his or her work, is to be reported.
They are not whistleblowing reports:
- Complaints, claims or personal requests relating to one's employment relationship (to be sent to the relevant company departments)
- Complaints or disputes concerning the services provided by the Company (to be sent to the relevant corporate functions
HOW TO REPORT?
INTERNAL REPORTING CHANNELS
Alerts can be made:
- by means of the specific computer tool Whistleblowing accessible by clicking here (https://hateburgroup.integrityline.io/?lang=it). The tool allows reports to be made in written form, by voice messaging, by uploading videos and photos, and by requesting a meeting with the report manager. By entering "Italy" in the first field of the message, the country-specific settings for Italy are activated and displayed in accordance with Decree 24/2023.
- orally, with a direct meeting with the Whistleblowing Committee or its representatives, to be requested in the "description of the report" field of the Portal. The content of the meeting will be recorded in a report drawn up by the reporting manager and signed by the whistleblower to confirm the accuracy of the report.
Who is the reporting manager?
The competent body for receiving and handling reports is the Whistleblowing Committee.
The Committee, while remaining the competent subject for the management of the report, may avail itself of the support of specifically authorised internal resources by means of a specific communication given in writing; moreover, in carrying out its preliminary investigation, the Committee may be supported by the relevant corporate organisational structures or by external professionals appointed for the purpose.
Should the report concern a member of the Committee, it will be handled by those members who are not in conflict and, therefore, excluding the one to whom the report refers.
THE EXTERNAL REPORTING CHANNEL AND PUBLIC DISCLOSURE
The internal management channel is to be used as a priority.
Whistleblowers may resort to the external channel managed by the National Anti-corruption Authority (ANAC), by connecting https://www.anticorruzione.it/-/whistleblowing, only in the following cases:
- the Company has not activated an internal reporting channel or this does not comply with Legislative Decree 24/2023;
- a report has already been made to the internal channel, but this was not followed up;
- the reporter has a well-founded fear that, if he/she used the internal channel, he/she would not receive effective follow-up or could be subjected to retaliation;
- the reporter has reasonable grounds to believe that the breach may constitute an imminent or obvious danger to the public interest.
Whistleblowers may also make public disclosure (press and other means of dissemination such as social networks) if one of the following conditions is met:
- the whistleblower 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 reporter has reasonable grounds to believe that the breach may constitute an imminent or obvious danger to the public interest;
- the whistleblower has well-founded reasons to believe that the external report may entail 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 whistleblower may be colluding with or involved in the violation.
The possibility of complaint to the competent national judicial and accounting authorities remains unaffected.
In implementation of the above, the Company has adopted the 'Procedure for Handling Whistleblowing Reports', which can be consulted here.
For an accomplished analysis:
- of persons who may issue alerts,
- of the subject of the alerts,
- of signalling channels,
- of how it is managed,
- of the protections afforded to whistleblowers, bona fide whistleblowers and other persons referred to in the provision
as well as for anything not indicated in this notice, please refer to the Procedure.