Procedure for managing whistleblowing reports

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Introduction

The purpose of the law on “Provisions for protecting those who report crimes or irregularities they came to know of during a public or private working relationship” (Official Journal, General Series 291 of 14 December 2017) is to encourage workers to help prevent actions or crimes that are in contrast with the ethical regulations of the company from appearing.  This page gives clear indications on the subject of the report, its contents, recipients and transmission methods, including the types of protection that is offered.

What to report

Reports can be made in the event of suspected incorrect behaviour or suspected unlawful actions or presumed violations, even ethical, that include:

  1. unlawful behaviour or violations of the organisation and management models;
  2. violation of the European standards on public tenders, services, products and financial products and markets, and prevention of recycling, financing terrorism, product safety and compliance, public health, consumer protection, the protection of a person’s private life, and the protection of personal data, network and computer system security;
  3. violation of the provisions on competition and State assistance.

Who can make a report and the relevant protections

Reports on violations in the person’s working environment or during a collaboration with Diquigiovanni Srl can be made by:

  1. employees (including fixed-term and part-time employees);
  2. those who collaborate with Diquigiovanni Srl;
  3. workers or collaborators who work for those who provide goods or services to, or who work in favour of, Diquigiovanni Srl;
  4. freelance workers and consultants who provide their services to Diquigiovanni Srl;
  5. volunteers and internists, paid and unpaid, who provide their services to Diquigiovanni Srl;;
  6. stakeholders and people with administrative, management, control, surveillance or representation roles. 

The reports can refer to facts or circumstances that the person came to know about:

  • while the working relationship or collaboration is in force; 
  • before the working relationship or collaboration started, if the information on the violations was acquired during the selection phase or other pre-contract phases;
  • during the trial period;
  • after the working relationship or collaboration has ended, if the information was acquired while the relationship or collaboration was active.

Whistleblowers can be sure that the privacy of their identity and the confidentiality of the information that appears in the report, from when it is received and during all its management phases, will be protected within the limits prescribed by provisions.

Any form of retaliation, discrimination or penalisation towards the whistleblower or anyone who took part in the investigation as a result of reasons connected, either directly or indirectly, to the report is forbidden.

Suitable forms of protection to guarantee confidentiality are involved, within the limits established by law, even regarding those who are presumed to be responsible for the behaviour or violations that were signalled.

Reporting methods

The portal is available 24 hours a day, 7 days a week.

It is managed by an independent provider, which guarantees high levels of confidentiality.

Reports can be made:

  • using the relative internal report channels: Register with the Whistleblowing portal and follow the procedure for sending your report;
  • using the external whistleblowing channel managed by ANAC;
  • through public divulgation using the press, or electronic means, or methods that can reach an elevated number of people. 

As an integration to these reporting methods, you can always turn directly to the Tribunal or Accounting Authority and present your report on the facts or behaviour you came to know about.