What can you report?
Conduct, acts, or omissions that harm the integrity of your organization. In particular, you can report:
- Violations of the Organization, Management, and Control Model pursuant to Legislative Decree No. 231/2001;
- Violations of EU law and the national transposing legislation.
Violations of EU law and national transposing legislation include:
- Offences related to public procurement, services, transport safety, food and feed safety, animal health and welfare, public health, money laundering, terrorist financing, financial services, products and markets, consumer protection, protection of the environment and personal data;
- Acts or omissions affecting the financial interests of the European Union (fraud, illegal activities);
- Acts and conduct that defeat the object or purpose of the provisions contained in Union acts;
- Violations of European Union rules on competition and State aid, acts violating corporate tax rules, or arrangements aimed at obtaining a tax advantage that defeats the object or purpose of the applicable corporate tax legislation;
What can you not report?
- Grievances, claims, or requests linked to a personal interest that relate to your employment relationship.
- Reports of violations where already mandatorily regulated by European Union or national acts.
Please note that, in any case, the limits provided for by national and European legislation regarding “classified information”—meaning information subject to a legal obligation of secrecy—remain in force.
For example, information covered by medical or legal professional privilege, as well as information concerning the deliberations of judicial bodies, cannot be reported.
What are your rights?
-> You have the right to confidentiality
Your identity cannot be disclosed to anyone other than those authorized to receive or follow up on reports. Confidentiality also extends to the identity of the persons involved and any persons mentioned in your report until the conclusion of the proceedings initiated as a result of the report.
-> You have the right not to suffer retaliation as a direct consequence of the report made.
The following behaviors are considered retaliatory actions:
Dismissal, disciplinary measures, suspension from work and/or pay, demotion, job transfer, changes to working hours, negative references, failure to promote, non-renewal or early termination of a fixed-term contract, loss of economic opportunities, damage to your reputation through content published, including on social media, early termination or cancellation of a contract for the supply of goods or services, and the revocation of a licence or permit.
Protection against retaliation also extends to:
- Anyone who assisted you during the reporting process.
- le persone del tuo medesimo contesto lavorativo e che siano a te legate da uno stabile legame affettivo o siano tuoi parenti entro il quarto grado
- People within your same work environment who have a close and stable personal relationship with you, or who are your relatives up to the fourth degree of kinship.
- Entities that you own, work for, or that operate within the same work environment as you.
You cannot be penalized.
If, at the time of reporting, you are required to disclose information that is necessary to establish the reported misconduct and that is protected by confidentiality obligations (other than legal professional privilege and medical confidentiality), or information relating to copyright protection or the protection of personal data.
How Can You Report?
You can use the following reporting channel:
- Through the internal reporting channel adopted by your organization (accessible at https://openimpact.trusty.report/ or via the button at the top of this page).
The report must clearly state:
- the identity of the reporting person (unless you choose to remain anonymous);
- the nature of your legal relationship with the organization;
- the time and place in which the reported incident occurred;
- a description of the facts;
- the identity of the person concerned, or any other information that would enable their identification in relation to the reported facts.
What Should You Expect After Submitting a Report?
You should receive an acknowledgement of receipt of your report within 7 days of its submission. Please note that, when submitting a report, you may request not to receive this acknowledgement if you believe that receiving it could compromise your confidentiality.
You may be asked to provide additional information or supporting documents to supplement your report.
Within 3 months of submitting your report (a period that may be extended up to 6 months where justified), you will receive feedback on the final outcome of the report.
For more information, visit http://www.anticorruzione.it/-/whistleblowing