What is “whistleblowing”?
The term whistleblowing refers to the voluntary disclosure by an individual, known as the “reporter” (or “whistleblower”—literally someone who blows the whistle, like a police officer or a referee to draw attention), of an unlawful act, violation, or irregularity committed within a company, of which they have either been a witness or have been informed.
How can I submit a report?
This company has provided a whistleblowing reporting platform accessible online at the following address:
https://private.mygovernance.it/mywhistleblowing/griven/76640
This platform ensures the confidentiality of the whistleblower’s identity and of any other individuals mentioned in the report, and protects the information transmitted through it by means of appropriate security measures. Reports may be submitted in written or oral form, or, at the whistleblower’s request, through a direct meeting with the person responsible for handling the report, which will be arranged within a reasonable timeframe.
Who can report?
Employees, managers, members of administrative and supervisory bodies, business partners, consultants, suppliers, and, in general, anyone who has or has had a working or business relationship with our company may submit a report. This also includes employees on probation or candidates still in the recruitment process, as well as former employees or collaborators, and former employees of clients or suppliers.
What can be reported?
Reports submitted through our Whistleblowing portal may concern unlawful acts or violations committed by individuals within our company, including breaches of laws and regulations, decisions of Authorities, internal procedures and company policies, as well as any conduct that may cause harm to the public or to consumers, of which the reporting person has become aware in the course of company activities.
The report must contain information useful for verifying the reported facts, meaning information that the reporting person has reasonable grounds to believe is true at the time of reporting.
What CANNOT be reported?
Claims or disputes of a purely personal nature related to employment relationships, as well as complaints concerning personal interests, will not be considered. For example: workplace conflicts, dissatisfaction with working conditions, organization or management of work, compensation, or personal grievances between colleagues or with supervisors. The reporting system must not be used as a tool to resolve personal workplace issues. Reports based on unfounded information, rumors, or unreliable hearsay are not permitted, nor are false or fabricated reports made with the intent to harm other individuals or the company.
Who handles my report?
Our company has appointed a designated person (the so-called Recipient or Report Manager) who is specifically authorized and trained to receive and manage reports, with the obligation to protect the confidentiality of the whistleblower and of any other individuals involved. The Recipient reviews the content of the report in order to verify the facts and enable the adoption of measures necessary to prevent or sanction any confirmed violations or misconduct. The Recipient is bound by confidentiality; depending on the reported facts, our company may not be informed prior to any legal proceedings.
How can I follow up on my report?
Within the reporting platform, you can choose your preferred communication channel for being contacted. You may also access your report periodically through the platform to check for responses or requests from the Recipient, or simply to monitor its status, by entering the 16-digit token issued at the time of submission, which is known only to the whistleblower. For confidentiality reasons, it is recommended not to use a company email address for follow-up communications.
Why should I submit a report?
Reports made in good faith and in the interest of the common good allow the company to promptly identify and address misconduct or violations that could otherwise escalate and harm the public. The whistleblowing system is an advantage for the company, as it strengthens internal control systems and provides an opportunity to detect potential fraud or critical issues before they result in more serious damage and/or liability.
What protections do I have as a whistleblower?
The whistleblower’s identity is kept confidential and is protected by law against any form of retaliation or discrimination that may result from the report. However, protection does not apply if the whistleblower has participated in the violation or misconduct.
Can reports be made anonymously?
Yes, anonymity is guaranteed. However, if you choose to disclose your identity when submitting a report, full confidentiality will still be ensured in accordance with applicable laws. Additionally, you may be informed about the outcome of the investigation process.
Is there protection against defamation or false reporting?
Reports must not contain false or fabricated allegations intended to harm the company or other individuals. False, malicious, or defamatory reports are prohibited and may be subject to legal sanctions. Individuals who intentionally submit such reports may face disciplinary action or be reported to the judicial authorities.
How are personal data processed?
The personal data of the whistleblower and of any other individuals involved in the report will be processed in compliance with applicable regulations. All information regarding the purposes and methods of data processing is available on the Whistleblowing portal.
