SYSTEMS FOR REPORTING IRREGULARITIES AND POLICIES

WHO CAN MAKE A REPORT?

The choice is left to the body / company. In general, in addition to employees,this can extend to all collaborators,
commercial partners, suppliers.

WHAT IS THE PURPOSE OF THE PROCEDURE? WHAT CAN YOU REPORT?

In this case, it is also the company’s choice. This generally includes all the behaviours that constitute or can constitute possible violations of laws, regulations and internal procedures of the company, including violations of the code of ethics. It can facilitate the understanding of the management procedure of the
reports the provision of some practical examples, the indication of some types of non-compliant behavior, possible subject of the report.

WHAT TYPE OF INFORMATION CAN THE REPORT CONTAIN?

The procedure must specify that a report, even in anonymous form, is not a complaint and must be sufficiently detailed, according to the elements acquired directly, in order to allowing a suitable response.

WHO IS DESIGNATED AS RECIPIENT OF THE REPORT?

Depending on how the institution is structured, the manager or an individual or specific function o específica (e.g., Internal audit, compliance manager, safety manager, member of the supervisory Body, etc.). In any case, the manager must be separate both in terms of budget and of management with respect to the worker.

WHAT CAN BE THE REPORTING CHANNELS?

You can choose a mailbox,a dedicated e-mail address, a telephone line and, where possible, an IT platform that can convey the message, favoring dialogue with the reporter in a context of confidentiality and security.

WHAT ARE THE OBLIGATIONS OF THOSE WHO RECEIVE A REPORT?

The receiver of the alert will perform a preliminary evaluation in terms of eligibility, and if this is the case, will start aninternal investigation, possibly consulting other corporate structures, while maintaining the confidentiality of the informing agent. He/she must then formulate a report which will be sent to the employer for possible internal measures. feedback periodici al segnalante e, sempre periodicamente, può essere utile comunicare i risultati della procedura e il suo funzionamento.

CAN YOU MAKE ANONYMOUS REPORTS?

It is possible to the extent that the journalists are informed that the reports must be as detailed as possible and that they cannot be considered in the absence of precise information.

WHAT ARE THE PROTECTIONS FOR THE JOURNALIST?

Firstly confidentiality of identity toward any person subject to the report, but also for third parties. With this aim, the necessary actions and initiatives must be taken against any person that imposes (or threatens) reprisals against the informer. The importance of the principle of protection of the informing agent should be also noted in the context of the Code of Ethics of the company, where it exists.

WHAT ARE THE PROTECTIONS FOR THE PERSON WHO IS THE OBJECT OF THE REPORT?

No disciplinary action must be taken against a person reported for the preparation of the report; only in the case that the report has been implemented internally.

CAN THE PROCEDURE PREPARE FOR THE SANCTIONS?

It not only can do so, but it must establish sanctions against those who abuse the procedure with deliberately defamatory information; toward the recipient of reports who does not carry out appropriate verification activities; against any other person that refuses to collaborate with the recipient designated for the verification of the reports or against those that commit or threaten reprisals against the informing agent.