Whistleblowing

Whistleblowing Regulations What can be reported Behaviors, acts or omissions that harm the public interest or the integrity of the public administration or private entity and which consist of: Administrative, accounting, civil or criminal offenses; Unlawful conduct relevant under Legislative Decree 231/2001, or violations of the organization and management models provided therein; Offenses that fall within the scope of application of European Union or national acts relating to the following sectors: Public procurement; Financial services, products and markets and prevention of money laundering and terrorist financing; Product safety and compliance; Transport safety; Environmental protection; Radiation protection and nuclear safety; Food and feed safety and animal health and welfare; Public health; Consumer protection; Protection of private life and protection of personal data and security of networks and information systems; Acts or omissions that harm the financial interests of the Union; Acts or omissions concerning the internal market; Acts or behaviors that nullify the object or purpose of the provisions of Union acts. What should not be the subject of "Whistleblowing Report" The following are excluded from the application of the regulations under examination: Disputes, claims or requests linked to a personal interest of the reporting person or of the person who has filed a complaint with the Judicial Authority that relate exclusively to their individual employment or public employment relationships, or inherent to their employment or public employment relationships with hierarchically superior figures (therefore excluded, for example, reports concerning labor disputes and pre-litigation phases, discrimination between colleagues, interpersonal conflicts between the reporting person and another worker or with hierarchical superiors, reports relating to data processing carried out in the context of the individual employment relationship in the absence of harm to the public interest or the integrity of the public administration or private entity); Reports of violations where already mandatorily regulated by European Union or national acts indicated in part II of the annex to the decree or by those national ones that constitute implementation of the European Union acts indicated in part II of the annex to directive (EU) 2019/1937, although not indicated in part II of the annex to the decree; Reports of violations in matters of national security, as well as contracts relating to defense or national security aspects, unless such aspects fall within the relevant derivative law of the European Union. Reporting Channels Internal; External (managed by A.N.A.C.); Public disclosure (through the press, electronic media or means of dissemination capable of reaching a large number of people); Complaint to the Judicial or Accounting Authority. Choice of Reporting Channel Reporters can use the external channel (ANAC) when: The mandatory activation of the internal reporting channel is not provided for within the work context or this, even if mandatory, is not active or, even if activated, is not compliant with what is required by law; The reporting person has already made an internal report and it has not been followed up; The reporting person has reasonable grounds to believe that, if they made an internal report, it would not be effectively followed up or that the same report could determine a risk of retaliation; The reporting person has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest; For more information regarding ANAC's competencies, please visit the Authority's website: https://www.anticorruzione.it/ Please Note: ANAC has provided for sanctions from €500 to €2,500 for reporters, in the event that the criminal responsibility of the reporting person is ascertained for the crimes of defamation or slander. Before proceeding with the report, I confirm that I have read and understood the regulations above and intend to proceed with the report. To proceed with the report, click on the following link: https://trusty.report/ The external channel managed by ANAC is available by accessing the link: https://whistleblowing.anticorruzione.it/#/ (We inform you that, in case of external reporting, this will be managed by ANAC in accordance with the "Regulation for the management of external reports and for the exercise of ANAC's sanctioning power in implementation of Legislative Decree 10 March 2023, n. 24. Resolution n. 301 of 12 July 2023"). Download the whistleblowing guidelines