whistleblowing

WHISTLEBLOWING PROCEDURE AT A GLANCE
Below are the main topics covered in the Whistleblowing procedure adopted by BATTAGLIA S.R.L., to which reference is made for completeness of information.

1. INTRODUCTION
   BATTAGLIA S.R.L. guarantees a working environment in which it is possible to freely report any unlawful conduct carried out within the Company.
2. WHO CAN REPORT
   The following may make reports:
   a) employees of private sector bodies;
   b) self-employed workers;
   c) workers and collaborators who provide goods or services or who carry out works for third parties;
   d) freelancers and consultants;
   e) volunteers and trainees;
   f) shareholders and persons with administrative, management, control, supervisory or representative functions (hereinafter, collectively, the "Recipients").

The aforementioned subjects may also make reports:

• when the legal relationship has not yet started, if the information on breaches was acquired during the selection process or at other pre-contractual stages;
• during the probationary period;
• after the dissolution of the legal relationship, if the information on the violations was acquired during the course of the relationship.

3. WHAT CAN BE REPORTED

Behaviours, acts or omissions that harm the public interest or the integrity of the Company and that consist of:

1. unlawful conduct, relevant pursuant to Legislative Decree 231/2001, or violations of the Organisation, Management and Control Model;
2. offences falling within the scope of European Union or national acts relating to the following areas:

• 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 protection of personal data and security of networks and information systems;

3. actions or omissions that harm the financial interests of the European Union, pursuant to Article 325 of the Treaty on the Functioning of the European Union;
4. actions or omissions concerning the internal market, referred to in art. 26, par. 2, of the Treaty on the Functioning of the European Union;
5. actions or conduct that defeat the object or purpose of the provisions of the acts of the European Union.
4. INTERNAL REPORTING CHANNELS ACTIVATED BY GIORGETTI S.P.A.
   
   4.1 HOW TO SEND THE REPORT

Type of Channel (written or oral)	Description of the reporting channel	Recipient and Manager of the report
Written	Portale on-line: ParrotWB	"The Whistleblowing Team of Labor Project"
Oral	Direct meeting	"The Whistleblowing Team of Labor Project"

for instructions on how to use internal reporting channels, please refer to the attachments to the Whistleblowing procedure

4.2 CONTENT OF THE REPORT

• the circumstances of the time and place in which the fact that is the subject of the report occurred;
• the description of the event;
• the general information or other elements that allow to identify the subject to attribute the reported facts.

4.3 REPORTING MANAGEMENT PROCESS

• receipt of reports: the recipient records the report and, within 7 days of receipt, sends the reporting party a notice of receipt;
• preliminary analysis of the reports: aimed at verifying the"admissibility" of the report. If yes, proceed to the next phase, otherwise, the report will be archived;
• investigation phase (assessment of reports): specific analyses are initiated, also through the involvement of other company figures involved and, if necessary, requesting further information from the whistleblower
• closure of reports: filing of the report or sending the report to the internal bodies or to the judicial authorities for any measures taken. Within 3 (three) months from the date of communication of the notice of receipt or, in the absence of such notice, within 3 (three) months from the expiry of the period of 7 (seven) days from the submission of the report, the manager of the report will provide a response to the whistleblower.

5. ADDITIONAL REPORTING CHANNELS

• External reporting channels activated by ANAC, portal accessible at the following link: https://servizi.anticorruzione.it/segnalazioni/#!/#%2F
• public disclosure
• complaint to the Judicial Authority

6. WHISTLEBLOWER PROTECTION

• CONFIDENTIALITY: confidentiality of the identity of the reporting person, the person involved and the person in any case mentioned in the report, as well as the content of the report and the related documentation
• PROTECTION MEASURES: any form of retaliation against the whistleblower is prohibited (e.g. any dismissal following the report is null)
• SUPPORT MEASURES: on the ANAC website, ANAC publishes the list of Third Sector entities that provide support measures to reporting persons consisting of information, assistance and advice on:

• reporting mode,
• protection from retaliation,
• rights of the person involved,
• terms and conditions of access to legal aid

 

PARROT WEB PLATFORM FOR REPORTS: https://giorgetti.parrotwb.app/

INSTRUCTIONS FOR SENDING THE REPORT VIA THE PARROT WEB DOWNLOAD PLATFORM DOWNLOAD

INSTRUCTIONS FOR SENDING THE REPORT BY DIRECT ENCOUNTER DOWNLOAD DOWNLOAD

 

Battaglia Information
According to ex. Article 13 GDPR for the whistleblower party DOWNLOAD

Battaglia Information
ex art. 14 GDPR for the reported subject DOWNLOAD