You can use our internal reporting channel to report suspected regulatory violations and wrongdoing related to our business organization, in accordance with Legislative Decree 24/2023.
What is whistleblowing?
Italian legislation on whistleblowing, updated with the transposition of the EU Directive 2019/1937, provides for the establishment of special channels and procedures at public and private sector employers to enable the reporting of violations to national and European regulations found in the work context.
The purpose of the aforementioned Directive is to enable whistleblowing by protecting the whistleblower from possible retaliation against him or her, thereby guaranteeing him or her appropriate protective measures with reference to the reported case and personal identity.
What can be reported?
The purpose of the reporting channel is to prevent and detect administrative, accounting, civil or criminal offenses, as well as violations of European Union Law and non-compliance with regulations in a varied range of areas of the business organization.
A report can also be about illegal, unethical, or harmful activities that may have a negative impact on others (e.g., financial crime and fraud; bribery and corruption; environmental crimes or health and safety risks; deliberate violations of the law, etc.).
The misconduct reported does not have to be current or ongoing, but an earlier occurrence or infractions that might be committed can also be reported.
When submitting a report, the reporting person must have a reasonable and well-founded reason to believe that the information about the reported violations is true and within the scope of the regulations.
It is emphasized that the purpose of this channel is not to express personal dissatisfaction with working conditions, organization, management, or conflicts in the workplace. Reports of this kind are generally not considered a case of whistleblowing.
Structure of reporting
The report should contain the following information:
- The type of irregularity you wish to report;
- Where the irregularity took place;
- when the irregularity took place (date and time and indicate whether the irregularity is recurrent);
- Documentation in any format, if accessible. If the documentation is not accessible, but you are aware of its existence, indicate the type of documentation and where it can be found;
- Details of any other action taken in connection with the irregularity.
No personal information should be sent that is not strictly relevant to the report. However, if they are sent, Isolcell S.p.A. reserves the right to delete such information without informing the reporter.
Treatment of the report
The person in charge or the office assigned to manage the whistleblowing channel is responsible for:
- Collect reports and issue a receipt acknowledging receipt of the report within 7 days of the report;
- follow up on the report, taking action to assess the existence of the reported facts, the outcome of the investigation and any measures taken;
- Provide feedback to the reporter about the outcome of the report within 3 months of receipt of the report.
The reporter can check the progress status of the report at any time by using the token (unique code) that will be automatically produced by the system when the report is opened.
Whistleblower and company will also be able to communicate via an anonymous chat system that ensures the identity of the whistleblower is protected.
It is also possible to report irregularities to external competent authorities (in Italy, the body in charge is ANAC) that can receive and follow up whistleblowing cases and provide feedback, as well as, where possible, to EU institutions, bodies and agencies.
Below is the link to access the ANAC external whistleblowing service → Whistleblowing – www.anticorruzione.it
Whistleblowers can use the external channel (ANAC) when:
- there is no provision within the work context for mandatory activation of the internal reporting channel, or this channel, even if mandatory, is not active or, even if activated, does not comply 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 he or she made an internal report, the report would not be effectively followed up or that the report itself could result in a risk of retaliation;
- the reporting person has reasonable grounds to believe that the violation may pose an imminent or obvious danger to the public interest.
Guarantee of anonymity
By submitting a report, the whistleblower is guaranteed complete anonymity unless he or she wishes to provide personal information voluntarily. However, it is not mandatory to provide personal information.
The identity of the reporting person may not be disclosed to persons other than those responsible for receiving and processing the report, unless there is explicit consent of the reporting person to the disclosure of his or her identity.
Should he or she wish, the reporter can decide for himself or herself to use additional tools to protect his or her digital identity during the course of reporting, such as incognito surfing and the use of VPNs.
Protecting the reporter from retaliation
The protections afforded to the whistleblower are protective measures designed to avoid retaliation as a result of reporting. This is provided that the report was made in the manner required by law and made in good faith, that is, at the time of the report the whistleblower had reason to believe that the violations were real.
In general, whistleblower protection is triggered where the whistleblower’s identity is revealed, thus making the risk of retaliation concrete.
A whistleblower who believes he or she has suffered employment discrimination as a result of a report may contact ANAC.