Our Company is particularly sensitive to the issue of protecting individuals who report violations of European Union law and national regulations.

Therefore, in compliance with legal obligations (Legislative Decree No. 24 of March 10, 2023), our Company has adopted its own internal reporting channel and related procedure to allow the whistleblower to submit their reports.

What can be reported?

1) Violation of national law, with reference to:
a) criminal, civil, administrative, or accounting offenses other than violations of European law;
b) unlawful conduct relevant to the application of Legislative Decree 231/2001 (so-called predicate offenses) or violation of organizational and management models pursuant to Legislative Decree 231/2001 other than violations of European law;

2) Violations of European law, with limited reference to:
a) Offenses committed in violation of European regulations, better specified in Annex 1 to Legislative Decree No. 24/2023 and all provisions implementing them even if not listed in the aforementioned annex, related 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; privacy and personal data protection and security of networks and information systems;
b) acts or omissions that harm the financial interests of the Union;
c) acts or omissions concerning the internal market, which compromise the free movement of goods, people, services, and capital, including violations of European Union rules on competition and state aid, as well as violations concerning the internal market related to acts that violate corporate tax rules or mechanisms aimed at obtaining a tax advantage that undermines the object or purpose of the applicable corporate tax legislation;
d) acts or behaviors that undermine the object or purpose of European Union provisions in the sectors mentioned above.

What is not subject to whistleblowing reporting?

1) Disputes, claims, or requests related to a personal interest of the reporting person or the person who has filed a complaint with the judicial authority that pertain exclusively to their individual employment or public employment relationships, or related to their employment or public employment relationships with hierarchically superior figures;

2) reports of violations where already mandatorily regulated by European Union acts and national implementing provisions that already guarantee appropriate reporting procedures;3) reports of violations concerning national security, as well as procurement related to defense or national security aspects, unless such aspects fall within the relevant derived law of the European Union.

Our internal reporting method

In digital written form through the dedicated digital platform: https://segnalazioni.termetritone.it/

Upon receiving the report, the manager:

– issues a receipt notice to the reporter through the platform, indicating a protocol number (i.e., a unique and personal numeric and/or alphanumeric code) at the time of completing the procedure and in any case within 7 days from the date of receipt;

– conducts a preliminary examination of the report to assess the legitimacy of the reporter and the essential requirements, as well as to evaluate whether the report falls within the scope of whistleblowing;

– following a positive outcome of the preliminary verification, the manager proceeds with the analysis of the internal investigation, requesting clarifications, documents, and additional information from the reporter; acquiring, if necessary, documents and information from other company offices; involving third parties or other company functions, who are obliged to cooperate with the manager; listening to any other internal/external parties, if necessary;

– at the conclusion of the investigation, the manager, within 3 months from the date of the receipt notice, provides feedback to the reporter regarding the archiving or validity of the report, detailing the measures planned or adopted or to be adopted to follow up on the report and the reasons for the decision made.

External reporting channel and public disclosure

he reporter can resort to the external channel activated at ANAC (https://whistleblowing.anticorruzione.it/#/), in the following cases:

– 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 pose 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.

Whereas public disclosure reporting can be made by the reporter only when the following conditions are met:

– the reporting person has previously made an internal and external report or has directly made an external report and no feedback has been provided within the established time limits regarding the measures planned or adopted to follow up on the reports;

– the reporting person has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest;

– the reporting person has reasonable grounds to believe that the external report may pose a risk of retaliation or may not be effectively followed up due to the specific circumstances of the case, such as those where evidence may be concealed or destroyed or where there is a well-founded fear that the recipient of the report may be colluding with the violator or involved in the violation itself.

To whom does the platform transmit the reports?

To the attention of the managers of the reporting channels, whom our company has identified as the internal personnel of:
– Federica Schiavolin at the Administration Office;
– Rossella Bragion at the Administration Office

Privacy notice

Our company is also particularly attentive to the protection of privacy and confidentiality concerning the treatment of the whistleblower, and to understand how the related data is processed, please refer to the company’s adopted privacy notice (Privacy Policy).