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Whistleblower - Alleged offences and irregularities reporting

On July 15th, 2023, d.lgs. 24/2023 became law, “Entrance in force of EU directive 2019/1937 del Parlamento europeo e del Consiglio, dd. Oct. 23rd 2019, referring to the protection of persons reporting violations of EU rights and displaying regulations pertaining the protection of persons reporting violations of national regulations”.

In accordance to such regulation, Fiscatech S.p.A. has adopted its own Whistleblowing Policy, by virtue of which its employees, stakeholders, as well as subjects not being part of the company organization, wanting to report significant violations (as defined in art. 2, comma 1 lett a. of D.Lgs. 24/2023), found or traceable within the Company structure, can proceed with such reporting, also using this dedicated form:

A) Open or confidential reporting (characterized by the express request of the whistleblower not to disclose his/her personal details), to be carried out:

  • Ordinary e-mail to the following e-mail address: segnalazionifiscatech@odvlawfirm.it;
  • Letter in a sealed envelope, addressed to: SB. Fiscatech S.p.A., c/o avv. Francesco Cioppa, via F. Filzi, n.2 - 20124 – Milan; i.e., to: SB. Fiscatech S.p.A., Via Biffignandi 37, - 27029 - Vigevano (PV);
  • By telephone to +39 340495027; orally or even in writing (messaging)

 

B) Anonymous reporting, to be carried out:

  • Formal letter, by ordinary or registered mail, without indicating the sender, to the Reporting Manager, namely: ODV Fiscatech S.p.A., avv. Francesco Cioppa, via F. Filzi 2, 20124 – Milan;
  • Anonymous letter to the box installed for this purpose and positioned in one of the common areas located within the operational headquarters of Fiscatech S.p.A., located in Via A. Oroboni, n. 41 - 27029 - Vigevano (PV) and at the plants located in via Montebello, 92 Vigevano (PV) and in via E. Fermi 27, Cormons (GO);

 

C) Open, confidential, or even anonymous report to be sent to ANAC (National Anti-Corruption Agency), in the cases indicated in art. 6 of Legislative Decree 24/2023, following the instructions you can find on the institutional website.

 

D) Reporting by public disclosure, to be carried out by public disclosure of the fact to be reported (through the press, electronic means, or multi-person media).

 

E) Direct complaint to the Judicial or Accounting Authority.

All reporting needs to be comprehensive and based on clear and reliable elements, while referring to verifiable fact, direct knowledge of the reporting person. In the same way, they need to contain all necessary information to identify the person(s) responsible of the illicit conduct.

The reporting party is therefore required to report in a clear and complete way all the elements useful for carrying out the checks and assessments necessary to assess their validity and objectivity, indicating, by way of example and not limited to:

  • references to the course of events (e.g. date, place) any information and/or evidence that can provide valid evidence about the existence of what has been reported;
  • personal details or other elements that make it possible to identify the person who committed the statement;
  • personal details of any other persons who may report on the facts covered by the Report;
  • any private interests related to the Report.

Even if the Company, in conformity with the Ethical Code, treats as preferable not-anonymous reporting, anonymous ones are still accepted, according to what stated in D. Lgs. 24/2023.
Anonymous reporting is accepted only when fully documented and able to reveal clear and determined facts and situations. They will be considered only when not appearing prima facie irrelevant, baseless or not fully documented.
In any case, good faith and truthfulness of facts of reported facts and situations are requested, in defense and protection of the reported person.
Before any reporting to the Responsible person in Fiscatech S.p.A., please read the informative note on treatment of personal data (up to art. 13, Regolamento 2016/679/UE - GDPR), which can be found here.