WHISTLEBLOWING

WHISTLEBLOWING REPORTS

THE INTERNAL WHISTLEBLOWING REPORT MANAGEMENT CHANNEL

Zeca S.p.A. has activated its own internal whistleblowing reporting channel, in compliance with the provisions of Legislative Decree 24/2023.

In order to regulate the process for managing whistleblowing reports, Zeca has adopted the “Whistleblowing” procedure, which can be consulted here, to which reference is made for the details indicated below.

Who are the whistleblowers?

The following individuals may submit reports:

  • subordinate workers;
  • workers with part-time, intermittent, fixed-term, agency, apprenticeship, accessory work contracts, volunteers and trainees, paid or unpaid, who work for the Company;
  • workers who carry out occasional services, self-employed workers, as well as freelancers and consultants who work for the Company;
  • the Company’s suppliers of goods and services;
  • the shareholders;
  • persons who, even de facto, hold administrative, management, control, supervisory or representative roles in the Company.

What can be reported?

The subject of reporting is behavior, acts, and omissions that harm the public interest or the integrity of the public administration and the Company, of which the reporting person becomes aware in the workplace, and which consist of:

  • violations of national or European Union regulatory provisions expressly provided for by Legislative Decree 24/2023;
  • unlawful conduct pursuant to Legislative Decree 231/2001 or violations of Model 231/2001. 

These are not whistleblowing reports:

  • Personal complaints, claims, or requests relating to your employment relationship (send to the relevant company departments)
  • Complaints or disputes relating to poor service from the Company (to be sent to the relevant company departments)
  • Information that is already entirely in the public domain
  • Information that is clearly unfounded, as well as information acquired only on the basis of unreliable rumours or hearsay (so-called corridor gossip).

What is the internal reporting channel?

Reports can be made through a specific IT platform accessible clicking here

The platform allows you to send reports:

  • in written form;
  • orally, via voice messaging, or by requesting a meeting with the report manager.

Who is the reporting manager?

The person responsible for receiving and managing reports is the President of the Supervisory Body. 

In carrying out the investigation, the reporting manager may avail himself of the support of specifically authorized internal resources or external professionals appointed for this purpose.

For reports falling within the scope of Legislative Decree 231/2001, the report manager informs the entire Supervisory Body.

EXTERNAL REPORTING CHANNEL AND PUBLIC DISCLOSURE

The internal management channel is to be used on an ordinary and priority basis. 

Reporters can make a report through the external channel managed by ANAC, by connecting to the sitehttps://www.anticorruzione.it/-/whistleblowing, only if:

  • the Company has not activated an internal reporting channel or this does not comply with Legislative Decree 24/2023;
  • a report has already been made to the internal channel, but this has not been followed up;
  • the whistleblower had a well-founded fear that if he or she used the internal channel, he or she would not receive effective follow-up or could be subjected to retaliation;
  • the whistleblower has reasonable grounds to believe that the violation may constitute an imminent or manifest danger to the public interest.

Ireporting entities may also make the report by means of public disclosure (es. stampa o social network), if the following conditions are met:

  • the whistleblower has previously made an internal and external report or has directly made an external report and no feedback has been given within the established timeframes regarding the measures envisaged or adopted to follow up on the reports;

  • the whistleblower has reasonable grounds to believe that the violation may constitute an imminent or manifest danger to the public interest;
  • the whistleblower has reasonable grounds to believe that the external report may entail the risk of retaliation or may not be effectively followed up due to the specific circumstances of the specific case, such as those in which evidence may be hidden or destroyed or in which there is a well-founded fear that the person who received the report may be in collusion with the perpetrator of the violation or involved in the violation itself. 

The possibility of reporting to the competent national judicial and accounting authorities remains unchanged.

For the privacy information click here

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