The Company Elettronica GF S.R.L. – P. Iva 02288800390, with its current registered office in Faenza – 48018 (RA), Via Ca’ Bianca n. 10 has equipped itself with an internal system of reporting wrongdoing in accordance with the requirements of Legislative Decree No. 24 of March 10, 2023, implementing the EU Directive 2019/1937 concerning the protection of persons who report violations of National and Union law and in order to create a positive image of transparency and trust as an essential element of a healthy corporate and organizational culture.

WHO CAN MAKE THE REPORT?

The reporting person – WHISTLEBLOWER – is the natural person who reports violations acquired in the context of his or her work environment. This definition includes all individuals who are even only temporarily in a working relationship with the company (employees, consultants, suppliers of goods and services, agents, contractors, business partners, shareholders, trainees and volunteers), even if they do not have the status of employees (such as volunteers, trainees, paid or unpaid) and, albeit under certain conditions, those who do not yet have a legal relationship with the Administration (in pre-contractual negotiations), as well as those whose relationship has ended or who are on probation.

THE LEGISLATION PROTECTS THE WHISTLEBLOWER AND PROVIDES FOR SANCTIONS IN THE EVENT OF RETALIATION AS A RESULT OF WHISTLEBLOWING, AND THE PROTECTIONS ALSO APPLY TO FACILITATORS, RELATIVES OR ASSOCIATES OF THE WHISTLEBLOWER, AS WELL AS INDIVIDUALS OWNED BY THE WHISTLEBLOWER OR OPERATING IN THE WHISTLEBLOWER’S WORK ENVIRONMENT.

WHAT CAN BE SUBJECT TO REPORTING?

The regulatory case is very broad, in accordance with the provisions of the Decree, the following can be reported:

VIOLATIONS OF NATIONAL LAW:

  • administrative, accounting, civil or criminal offenses;
  • unlawful conduct relevant under Legislative Decree No. 231/2001;

VIOLATIONS OF EUROPEAN LAW:

  • offenses that fall within the scope of application of European Union acts relating to the following areas:
    – public procurement;
    – financial services, products and markets;
    – 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 personal data protection;
    – security of networks and information systems;
  • acts or omissions affecting the financial interests of the European Union;
  • acts or omissions concerning the internal market, which undermine the free movement of goods, persons, services and capital;
  • acts or conduct that frustrate the object or purpose of the provisions referred to in the acts of the European Union.

DISPUTES, CLAIMS OR DEMANDS RELATED TO AN INTEREST OF A MERELY PERSONAL NATURE OF THE REPORTER MAY NOT BE REPORTED.

WHO WILL TAKE CHARGE OF THE REPORT?

The Whistleblower Manager/Instructor is the person functionally in charge of receiving and taking charge of the reports (within 7 days), assessing the existence of the eligibility requirements of the reports, initiating the relevant investigation, maintaining interlocutions with the whistleblower, and giving feedback to the whistleblower within three months from the date of notice of receipt of the report.

THE IDENTITY OF THE WHISTLEBLOWER WILL NOT BE DISCLOSED UNLESS PRIOR CONSENT HAS BEEN GATHERED FROM THE WHISTLEBLOWER.

HOW CAN I MAKE A REPORT?

Reports can be made in the following ways:

  • ANONYMOUS: not allowing association of the report with the name of the reporter, In this case the reporter is not required to register with the system and can submit the report as an unregistered user in the “Report without registration” section;
  • CONFIDENTIAL: Allowing for identification of the reporter, in this case the report requires prior registration of the user and then, once the account is created, the user can send the report. It is also possible to submit a confidential report without creating an account by filling out the report form from the “Report without registration” section and indicating personal data at the end of the form. The data of the reporter are separate from the report so the confidential report is sent to the Manager anonymously.

Reports can be made through special platform, accessible at the following https://elettronicagf.segnalazioni.net, which guarantees the confidentiality of the identity of the reporter and the information contained in the report through encryption systems; the report is accessible only to the reporter and the Whistleblowing Manager.

The management and processing of any personal data provided will take place in accordance with the rules of the European Regulation 679/2016 and the information contained therein and available at https://elettronicagf.segnalazioni.net/pages/privacy.

Technical instructions on how to proceed with whistleblowing can be found within the platform or at the following link: https://manuali.digitalpa.it/whistleblowing/v4-0-0/frontend/registrazione.html.

For further details and insights please refer to the corporate whistleblowing policy available within the platform and at the following link https://elettronicagf.segnalazioni.net/pages/policy.