Whistleblowing - Reporting pathway
In order to promote the culture of legality and condemn any form of wrongdoing, Eurolls S.p.A. has adopted the Whistleblowing tool in accordance with the provisions of Legislative Decree 24/2023, to encourage employees, collaborators, suppliers, and any other stakeholder to report any violation or irregularity, ensuring the protection of the confidentiality of the whistleblower and protection from retaliation.
The term Whistleblowing, in particular, refers to the reporting of conduct, acts or omissions, in violation of national or European Union regulatory provisions that harm the public interest or the integrity of the Company, carried out by a person who has become aware of it in the context of his or her work context.
The term Whistleblowing, in particular, refers to the reporting of conduct, acts or omissions, in violation of national or European Union regulatory provisions that harm the public interest or the integrity of the Company, carried out by a person who has become aware of it in the context of his or her work context.
The conditions and procedures for sending and managing Eurolls S.p.A.'s reports are better regulated in the Whistleblowing Procedure below. By proceeding with the submission of a report, you declare that you have read and understood the information on the processing of personal data in the event of whistleblowing reports (Whistleblowing Privacy Policy).
EUROLLS S.P.A. (hereinafter referred to as the "Company") considers it essential to comply with the rules and regulations as well as the Code of Ethics adopted.
In this context and in compliance with the provisions of Legislative Decree no. 24/2023, which implemented Directive (EU) 2019/1937 on "Whistleblowing", the Company has activated suitable internal reporting channels, in particular through the use of a special platform, available at https://segnalazioni.eurolls.com/, in order to ensure the protection and confidentiality of both the reporting persons and the persons involved as well as the content of the reports, without prejudice to the possibility of arranging a face-to-face meeting.
The above-mentioned reporting channels allow data subjects to report to the recipient Company, even anonymously, reports on violations of national or European Union regulatory provisions that harm the public interest or the integrity of the Company, as well as relevant unlawful conduct pursuant to Legislative Decree 231/2001 or violations of the Organization, Management and Control Model, of which they have become aware within their own work context.
In addition to the internal reporting channels, under certain conditions, the reporting person may make an external report, pursuant to art. 6 et seq. of Legislative Decree no. 24/2023.
The whistleblowing system is available to whistleblowers if they have sufficient grounds to believe that the reports are truthful, based on the factual circumstances and the information available to them. In order to be able to investigate reports, we need specific information about specific facts.
EUROLLS S.P.A. (hereinafter referred to as the "Company") considers it essential to comply with the rules and regulations as well as the Code of Ethics adopted.
In this context and in compliance with the provisions of Legislative Decree no. 24/2023, which implemented Directive (EU) 2019/1937 on "Whistleblowing", the Company has activated suitable internal reporting channels, in particular through the use of a special platform, available at https://segnalazioni.eurolls.com/, in order to ensure the protection and confidentiality of both the reporting persons and the persons involved as well as the content of the reports, without prejudice to the possibility of arranging a face-to-face meeting.
The above-mentioned reporting channels allow data subjects to report to the recipient Company, even anonymously, reports on violations of national or European Union regulatory provisions that harm the public interest or the integrity of the Company, as well as relevant unlawful conduct pursuant to Legislative Decree 231/2001 or violations of the Organization, Management and Control Model, of which they have become aware within their own work context.
In addition to the internal reporting channels, under certain conditions, the reporting person may make an external report, pursuant to art. 6 et seq. of Legislative Decree no. 24/2023.
How can my report help?
The purpose of reporting is to investigate illegal and unethical situations, to identify risks in a timely manner and to prevent potential damage to the company's reputation. In this way, it can help to minimise the risks for the company and all its employees.The whistleblowing system is available to whistleblowers if they have sufficient grounds to believe that the reports are truthful, based on the factual circumstances and the information available to them. In order to be able to investigate reports, we need specific information about specific facts.
Who can make a report?
The whistleblowing legislation, with the related protections, applies to the following categories of people who report violations of which they have become aware in the context of their work context:- employees, in any capacity, of the Company;
- self-employed workers, including those referred to in Chapter I of Law no. 81/2017, as well as holders of a collaboration relationship referred to in art. 409 c.p.c. and Article 2 of Legislative Decree 81/2015, who carry out their work activities in favour of the Company;
- workers and collaborators of companies that supply goods or services and carry out works in favour of the Company;
- freelancers and consultants who work for the Company;
- trainees, both paid and unpaid, who work for the Company;
- the Company's customers, potential customers, agents and partners;
- shareholders and persons with administrative, managerial, controlled, supervisory or representative functions in favour of EUROLLS, even if such functions are exercised on a purely factual basis.
The protection of reporting persons also applies if the report is made in the following cases:
- when the legal relationship has not yet begun, if the information on the violations was acquired during the selection process or at other pre-contractual stages;
- during the probationary period;
- after the termination of the legal relationship, if the information on the violations was acquired during the course of the relationship.
What kind of behaviors should I report?
You can submit a report if in your work context you have become aware of conduct or events that may constitute violations of national or European Union regulatory provisions that harm the public interest or the integrity of the Company.
On the other hand, the whistleblowing legislation, with the related protections, does not apply to disputes, claims or requests related to a personal interest of the reporting person that relate exclusively to their individual employment relationships.
In particular, the violations reported may consist of:
On the other hand, the whistleblowing legislation, with the related protections, does not apply to disputes, claims or requests related to a personal interest of the reporting person that relate exclusively to their individual employment relationships.
In particular, the violations reported may consist of:
- violations of laws and regulations;
- violations of official orders;
- violations of Model 231/2001, both in the General and Special Parts;
- violations of company contracts and procedures;
- human rights violations (including reports of harassment, abuse, including verbal abuse, bullying);
- behaviour that causes damage or prejudice, even if only to the image;
- any other violations in relation to the provisions of the Company's Code of Ethics.
How do I submit an internal report?
A report can be sent through the secure web platform of a specialized company independent of the Company, which can be reached through the link in this section of the website. Alternatively, a verbal report (telephone) can be sent to the number 0432 296056 (number of the managing entity) which can also be used to request an appointment in person with the entity managing the reports.
What happens after a report?
All reports are received and managed by the managing body, appointed by the Company by an act of its Board of Directors.
After submitting a report, the reporting person:
After submitting a report, the reporting person:
- receives acknowledgment of receipt of the report within seven days from the date of receipt;
- may be further contacted to provide the managing entity with information, additions or clarifications;
- receive a reply to the report within three months of the date of the acknowledgement of receipt or, in the absence of such acknowledgement, within three months of the expiry of the period of seven days from the submission of the alert.
Is it possible to submit a report anonymously?
Yes, you can submit a report anonymously.
Information on the channel, procedures and requirements for making external reports
The reporting person can make an external report through the channel set up at the National Anti-Corruption Authority (ANAC) when:
- there is no mandatory activation of the internal reporting channel within its work context, i.e. this, even if mandatory, is not active or, even if activated, does not comply with Legislative Decree 24/2023;
- the reporting person has already made an internal report and the same has not been followed up; the reporting person has reasonable grounds to believe that, if the reporting person were to make an internal report, it would not be effectively followed up or that the report could lead to a risk of retaliation;
- The reporting person has reasonable grounds to believe that the breach may constitute an imminent or obvious danger to the public interest.
For details on the operation and access to ANAC's external channel, please refer to the www.anticorruzione.it/-/whistleblowing website.
In addition, the reporting person may resort to public disclosure, but only and exclusively in the cases expressly provided for by law. Failure to do so will result in the protection afforded to the whistleblower. The hypotheses admitted are the following:
In addition, the reporting person may resort to public disclosure, but only and exclusively in the cases expressly provided for by law. Failure to do so will result in the protection afforded to the whistleblower. The hypotheses admitted are the following:
- the reporting person has previously made an internal and external report or has directly made an external report and has not been responded to within the terms provided for by current legislation regarding the measures envisaged or adopted to follow up on the reports;
- the reporting person has reasonable grounds to believe that the breach may constitute an imminent or obvious danger to the public interest;
- The reporting person has reasonable grounds to believe that the external report may entail 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 person receiving the report may be colluding with or involved in the violator.
In the context described above, the whistleblower has the right to apply to the judicial or accounting authority.
Are there any forms of protection for the whistleblower?
The person who makes a report enjoys the widest protection of his or her confidentiality, also extended to other subjects provided for by current legislation, i.e. facilitators (natural person who assists the whistleblower in making the report and who operates in the same work context), colleagues of the whistleblower and those who operate in the same work context, as well as entities owned by the whistleblower.
Furthermore, the whistleblower cannot suffer any form of retaliation due to the report made and, should this occur, without prejudice to ANAC's powers of intervention and sanctions, the Company itself is required to remedy this situation with the necessary initiatives aimed at:
on the one hand, to protect the whistleblower and to stop the vexatious conduct in which he has incurred or to render ineffective any measures taken to his detriment (by way of example but not limited to), demotion, change of functions, failure to convert the contract from fixed-term to open-ended;
on the other hand, to impose sanctions under the company's disciplinary system against those who have put them in place.
The same protections are also offered in the event that recourse has also been made to the external channel, disclosure and reporting.
In all cases, no protections are offered and, on the contrary, sanctioning measures are provided for those who make an unfounded report with intent or gross negligence, with verification to this effect by the judicial authority.
Furthermore, the whistleblower cannot suffer any form of retaliation due to the report made and, should this occur, without prejudice to ANAC's powers of intervention and sanctions, the Company itself is required to remedy this situation with the necessary initiatives aimed at:
on the one hand, to protect the whistleblower and to stop the vexatious conduct in which he has incurred or to render ineffective any measures taken to his detriment (by way of example but not limited to), demotion, change of functions, failure to convert the contract from fixed-term to open-ended;
on the other hand, to impose sanctions under the company's disciplinary system against those who have put them in place.
The same protections are also offered in the event that recourse has also been made to the external channel, disclosure and reporting.
In all cases, no protections are offered and, on the contrary, sanctioning measures are provided for those who make an unfounded report with intent or gross negligence, with verification to this effect by the judicial authority.