OPERATIONAL GUIDE FOR WORKERS
1. INTRODUCTION
In order to promote values of trust, responsibility, and confidentiality and to prevent any irregularities, Elisabet s.r.l. has taken steps pursuant to Art. 4 of Legislative Decree no. 24/2023 for the establishment of an internal violation reporting channel (whistleblowing), which meets the requirements of the legislation, to report alleged anomalies or breaches found at the company.
2. WHISTLEBLOWER – REPORTER
Reports may be made by employees, former employees, job applicants, shareholders, members of corporate bodies, external collaborators, and suppliers (for more information, see Art. 3 of Legislative Decree no. 24/2023).
3. WHAT TO REPORT
Breaches of national or EU regulatory provisions that harm the public interest or the integrity of the private entity that come to the knowledge of the private entity in the work context, such as
1. offences relating to the following areas: public contracts; 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; privacy and protection of personal data and security of networks and information systems;
2. acts or omissions detrimental to the financial interests of the European Union;
3. acts or omissions relating to the internal market that jeopardise the free movement of goods, persons, services and capital;
4. acts or conduct that frustrate the object or purpose of the provisions of the European Union;
5. relevant offences pursuant to legislative decree no. 231 of 2001.
6. violations of the organisation and management model
They do not constitute so-called whistleblowing reports (Art.1 Legislative Decree 24/2023):
1. objections, claims or demands linked to an interest of a personal nature of the whistleblower that relate exclusively to their individual employment relationship, or inherent in their relationship with hierarchically superior figures;
2. Cases covered by national defence secrecy;
3. Alleged organisational inefficiencies;
4. Medical or professional secret.
4. REPORTING CHANNELS
Reports can be made using the following methods:
WRITTEN REPORT
By sending the provided form ‘M35 – NOTIFICATION OF WRONGDOING FOR WHISTLEBLOWER’ in known or anonymous form by hard copy mail (by registered post with return receipt) to the address at
➢ Mr Alessandro Piersanti, via Corva, 56 – 63821 Porto Sant’Elpidio (FM);
➢ or in a known form by email to the Supervisory Board’s mailbox ([email protected]), the user id and password of which are known exclusively to the Supervisory Board itself (it should be noted that this channel is not considered secure for the purposes of guaranteeing confidentiality).
VERBAL REPORT
verbally (in person or by telephone: +39 328.3664808), by means of a statement issued and recorded in the minutes by the Supervisory Board;
In addition, the reporting person may make an external report to the competent authorities (ANAC) and/or a public disclosure within the limits and in the manner laid down by Legislative Decree no. 24/2023.
5. WHO MANAGES THE REPORT
The person in charge of the internal reporting system handles the reports received and may request the involvement of other corporate functions only if absolutely necessary (need-to-know) and in compliance with the confidentiality and protection of the personal data processed.
The Whistleblower will be notified of receipt of the report (within 7 working days), the admissibility of the report, and its closure (approximately 3 months).
6. PROCESSING OF PERSONAL DATA
With specific regard to the processing of personal data, please refer to the ‘INFORMATION ON THE PROCESSING OF PERSONAL DATA IN CONNECTION WITH “WHISTLEBLOWING” REPORTS’
(attached).
7. PROTECTION OF THE REPORTER
1. Confidentiality – The identity of the whistleblower and those involved are treated as strictly confidential.
2. Reporting can also be done anonymously.
3. Prohibition of any direct or indirect form of discriminatory, retaliatory or omissive behaviour towards the whistleblower or related third parties such as employees, colleagues, etc.
USEFUL LINKS
Reporting form
Privacy information
Privacy information for the person involved