Whistleblowing
WHISTLEBLOWING POLICY
Following the entry into force of Legislative Decree no. 24/2023 (hereinafter the "Decree"), concerning "the protection of persons reporting violations of Union law and containing provisions regarding the protection of persons reporting violations of national regulations" of which they have become aware in a public or private workplace context (so-called "whistleblowing" legislation), Roberto Collina Srl (hereinafter the "Company") has implemented a dedicated internal reporting channel for the management and transmission of reports. The aim is to promptly identify and remedy unlawful acts that may harm the interests and integrity of the Company, ensuring the confidentiality of the whistleblower's identity and protection from any retaliation related to the reports made.
On this basis, the Company has adopted an IT platform for receiving and managing whistleblowing reports, designed to guarantee the confidentiality of the reporting persons, the reports and the related documentation through End-to-End (E2E) encryption. The platform can be accessed at the following address: https://scswhistleblowing.com/robertocollina/form .
This platform, developed in accordance with the Decree, Regulation (EU) 2016/679, and Legislative Decree no. 196 of June 30, 2003, will allow the reporting person to formalize the whistleblowing report in writing, via voice messaging, or in a face-to-face meeting with the person specifically responsible for managing the internal reporting channel, identified by the Organizational Act adopted by the administrative body. This person will be responsible for providing timely feedback to the reporting person and ensuring the appropriate follow-up is given to the reports received.
Reporters who act in good faith, based on a reasonable belief in the veracity of the information on reported violations, are legally protected from retaliation, as well as limited liability for the disclosure and dissemination of certain categories of information.
Finally, it is recalled that, subject to the use of the internal reporting channel, the reporting person is legally entitled to formalize the whistleblowing report by addressing it directly to the ANAC (National Anti-Corruption Authority) if the manager identified by the administrative body with an Organizational Act has failed to follow up on the whistleblowing report, or if the reporting person has reasonable grounds to believe that filing an internal report would result in retaliation, or that the violation could constitute an imminent or manifest danger to the public interest.
For further information regarding the persons authorized to submit reports, the purpose and content of the reports, as well as the specific protections recognized by the Decree for the persons involved in the reporting process, please refer to the following documents: