Whistleblowing
In implementation of Directive (EU) 2019/1937, Legislative Decree no. 24 of 10 March 2023 (hereinafter also referred to as the ``Decree``) was issued concerning "the protection of persons reporting violations of Union law and containing provisions regarding the protection of persons reporting violations of national regulatory provisions". The Decree collects in a single legislative text the entire regulation of reporting channels and protections recognized to whistleblowers in both the public and private sectors, resulting in an organic and uniform regulation aimed at greater protection of the whistleblower.
WHO CAN SEND A REPORT
- The following are entitled to report persons who come into contact with STIMM Srl in a work context, namely:
- company personnel: managers, employees, including those on probation, and temporary workers;
- collaborators, consultants and freelancers;
- volunteers and interns;
any other subject indicated in art. 3 of the Decree, for example: participants in a selection, shareholders, persons with administrative, management, control, supervisory or representative functions.
WHAT CAN BE REPORTED
Behaviors, acts or omissions that harm the interests or integrity of the company STIMM Srl which consist of:
- administrative, accounting, civil or criminal offences;
- unlawful conduct relevant pursuant to Legislative Decree 231/2001 and violations of the company's internal organisation and/or regulation model;
- offences falling within the scope of European Union or national acts relating to the following sectors:
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public procurement;
- financial services, products and markets and prevention of money laundering and terrorist financing;
- product safety and compliance;
- transport safety;
- environmental protection;
- radiation protection and nuclear safety;
- food and feed safety and animal health and welfare;
- public health;
- consumer protection;
- protection of privacy and personal data protection and security of networks and information systems;
- acts or omissions which harm the financial interests of the Union;
- acts or omissions relating to the internal market;
- acts or behaviours which frustrate the object or purpose of the provisions of the Union acts.
Only reports that concern facts found directly by the reporter, not based on current rumours, founded on precise and consistent factual elements, will be taken into consideration.
The report must not concern personal complaints.
REPORTING CHANNELS
The Decree provides that reports can be made through the following reporting channels:
- internal: managed by the Company;
- external: managed by the National Anti-Corruption Authority ( ANAC ) and usable when the conditions indicated by the Decree exist.
HOW TO MAKE AN INTERNAL REPORT
Reporting can take place in:
WRITTEN FORM
- Electronic submission by accessing the dedicated online platform WHISTLI by Ecloga Italia Spa at the following link: https://app.whistli.it/report/80a3eb-bjpn-vexyc9 ;
- Send a written report using the appropriate Report Form downloadable at the end of the page. The report, inserted in a sealed envelope, must be addressed to:
STIMM Srl
Via Conegliano 35/3
31053 – Pieve di Soligo – Italy
ORAL FORM
Upon request of the reporting person, through a confidential direct meeting (and release of a statement) with the person responsible for the procedure within 10 days, after making an appointment (for more information write to: accounting01@roadgroup.it).
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All channels guarantee data security and protection and confidentiality of information.
STIMM Srl has established a specific procedure for receiving, analyzing and processing reports: