WHISTLEBLOWING
Legislative Decree No. 24 of 10 March 2023
WHAT IS WHISTEBLOWING
❖”Whistleblowing” is the regulation of procedures to encourage and protect whistleblowing.
❖”Whistleblower” is a person who becomes aware of a wrongdoing or irregularity in the workplace, during the performance of his or her duties, and decides to report it to a person or authority that can act effectively on the matter, playing a role of private and public interest, making the company or community aware of problems or dangers.
CAN I REPORT?
Reports can be made by:
– employees and self-employed workers of Nuova Lofra srl
– collaborators, freelancers, consultants
– volunteers, trainees;
– shareholders and persons with management, administration and control functions.
The discipline also applies to reports concerning breaches made in the context of an employment relationship that has subsequently ended; as well as to those whose relationship has not yet begun, if information on breaches has been acquired during the selection process, or in other pre-contractual stages.
WHAT CAN YOU REPORT?
✓ Administrative, civil, criminal and accounting offences.
✓ Violations relating to public procurement, services, products and financial markets, and offences related to money laundering and terrorist financing.
✓ Issues related to product safety and compliance, transport safety.
✓ Issues relating to environmental protection, radiation protection and nuclear safety.
✓ Food and feed safety risks, animal welfare, public health and consumer protection.
✓ Violations of privacy, personal data management and security of networks and information systems.
✓ Actions or omissions detrimental to the Union’s financial interests, competitive practices and state aid, and corporate tax issues.
WHAT CAN’T YOU REPORT?
Complaints linked to a personal interest of the reporter, which relate to the relationships
✓ individual employment relationships;
✓ relating to defence and national security;
✓ relating to violations already regulated in certain special sectors (financial services, money laundering prevention, terrorism, transport safety, environmental protection).
✓ The regulations on classified information, medical and forensic secrecy and court deliberations remain unaffected.
WHO WILL BE INFORMED OF MY REPORT?
In line with art. 4 of Legislative Decree 24/2023, the management of the reporting system has been entrusted by Lofra srl to an internal person specifically trained to manage the reporting channel and to an external collaborator who supervises the activity for your greater protection. Only those responsible for reporting, appointed by Nuova Lofra srl, will be aware of your report.
CAN YOU REPORT ANONYMOUSLY?
Yes, it is possible to report anonymously, although knowledge of the reporter’s identity simplifies internal investigations and allows requests for clarification. In addition, only those who declare their identity can benefit from the protection provided by Legislative Decree No. 24 of 10 March 2023 Implementing Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law and laying down provisions on the protection of persons who report breaches of national laws.
IF I QUALIFY, WHO WILL BE INFORMED OF MY IDENTITY?
Only the Reporting Officers will have access to your identity. Other people will only know your identity with your explicit consent.
WHAT RESPONSIBILITY DO I HAVE FOR MY REPORT?
Your main responsibility is to provide truthful information, avoiding the use of offensive language and referring only to facts or circumstances relevant to your work context.
WHEN CAN I EXPECT A RESPONSE?
Within 7 days of the report you will receive an acknowledgement. Within 3 months of the report you will receive feedback on the outcome.
WHAT IF I DO NOT RECEIVE ANY FEEDBACK?
You can inform ANAC through the platform on the institutional website.
HOW WILL MY DATA BE PROCESSED?
The processing of your personal data must be conducted in accordance with Regulation (EU) 2016/679, Legislative Decree of 30 June 2003, n.196 and Legislative Decree of 18 May 2018, n.51. Personal data that is not clearly useful for the processing of a specific report will not be collected or, if collected in error, will be deleted immediately. For a full disclosure please refer to the following link.
WHAT WILL HAPPEN AFTER MY REPORT?
The Reporting Officers will conduct appropriate investigations to ascertain the admissibility and veracity of the report.
CAN RETALIATION OR ANY FORM OF REPRISAL OCCUR BECAUSE OF MY REPORT?
There will be no retaliation on the part of the Company, except for bad faith or defamatory behaviour. Please note that in case of retaliation and/or reprisal you can report it to the ANAC.
HOW CAN I MAKE A REPORT?
Nuova Lofra srl provides a form and instructions for reporting, as well as information on privacy. You can use the Trusty platform on the company website or send your report by post.
HOW THE TRUSTY ONLINE PLATFORM WORKS
The platform ensures confidentiality through the use of encryption. You can report via the company website by filling in the fields and saving your credentials. The link is available at the bottom of this page.
WHERE CAN I FIND OUT MORE?
Nuova Lofra srl has adopted its own internal regulations, which can be read at the following link. Please refer in any case to Legislative Decree No. 24 of 10 March 2023 Implementing Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law and on the protection of persons who report breaches of national laws.
