Pursuant to Legislative Decree 24/2023, Faeda SpA has implemented its own platform to report behaviors, acts or omissions that harm the public interest or the integrity of the public administration or private entity, guaranteeing confidentiality and the protections provided for the whistleblower.

What can be reported

Violations of national or EU regulations that harm the public interest or the integrity of the public administration or private entity that has come to light in the work context and which consist of:

• administrative, accounting, civil or criminal offences; significant unlawful conduct pursuant to Legislative Decree 231/2001, or violations of the organisation and management models provided for therein;
• offences falling within the scope of Union or national acts relating to the following areas: public procurement; financial services, products and markets and the 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;
• Actions or omissions that affect the financial interests of the European Union;
• Actions or omissions that afffect the internal market;
• acts or conduct which undermine the object or purpose of the provisions of Union acts.

Signalling channels

• Internal channel made available by Faeda SpA;
• external (ANAC);
• public disclosure (through the press, electronic means or means of dissemination capable of reaching a large number of people) only if the conditions referred to in art. 15 Legislative Decree 24/2023 (link);

The whistleblowers are required to use the internal channel, developed according to the highest security standards available to guarantee the protection of the rights of the whistleblower, except in the cases expressly provided for by art. 6 in which the whistleblower can contact the ANAC directly (with link to the pdf of the decree)

Content of notification

The whistleblower is required to provide all the useful elements to allow the competent offices to carry out the necessary and appropriate checks to confirm the substantiation of the facts that are the subject of the report. To this end, the Report should preferably contain the following elements:

1. (a) details of the person making the alert indicating the position or function carried out within the undertaking, or other link with it;
2. a clear and complete description of the facts subject to reporting;
3. (c) if known, the circumstances of the time and place in which they were committed;
4. d) if known, the general information or other elements (such as the qualification and the service in which the activity is carried out) that make it possible to identify the person who carried out the event or events that are the subject of the report;
5. the indication of any other subjects who can report on the facts subject to reporting;
6. the indication of any documents that can confirm the validity of these facts;
7. any other information that can provide useful feedback on the existence of the facts reported.

Methods of management of reports by Faeda SPA

• we notify the reporting person of the receipt of the report within 7 days from the date of its receipt;
• we maintain discussions with the reporting person and request from the latter, if necessary, additions and/or clarifications useful to better manage the report;
• we diligently follow up on the reports received;
• we carry out the necessary investigation to follow up on the report;
• we inform the reporting person of the final outcome within three months of the notification of receipt of the report.

Anonymous reports are allowed by the decree but Faeda S.p.A. does not recommend their use as they hinder both the dialogue with the reporter and the correct conduct of the procedure.

Subjects whose confidentiality is protected

The identity of the whistleblower may not be disclosed to persons other than those competent to receive or follow up on the reports.

The protection concerns not only the name of the whistleblower, but also all the elements of the report from which the identification of the whistleblower can be derived, even indirectly.

The alert shall be removed from access to administrative acts and the right of general civic access.

The protection of confidentiality is extended to the identity of the persons involved (reported) and of the persons mentioned in the report as well as to the facilitators, persons of the same work context and to the reporting person’s work colleagues, in compliance with the same guarantees provided in favour of the reporting person.

Protection is ensured if:

1. a) at the time of reporting or reporting to the judicial or accounting authority or of public disclosure, the reporting person or whistleblower had reason to believe that the information on the reported, publicly disclosed or reported violations was true and within the objective scope of the report (art. 1 co 1 D. Lgs. 24/23);
2. b) the reporting or public disclosure has been carried out on the basis of the provisions of Chapter II of Legislative Decree 24/23, or with the channels and conditions identified therein.

Except for the specific limitations of liability provided for in Article 20 of Legislative Decree 24/23, when the criminal liability of the reporting person for the offences of defamation or slander or in any case for the same offences committed with the complaint to the judicial or accounting authority or his civil liabilityis ascertained, for the same reason, in cases of wilful misconduct or gross negligence, the confidentiality protections are not guaranteed and the reporting person or reporting person is subject to a disciplinary sanction.

The processing of personal data relating to the receipt and management of reports is carried out by Faeda SpA, as data controller, in compliance with European and national principles regarding the protection of personal data, providing appropriate information to the reporting persons and persons involved in the reports, as well as adopting appropriate measures to protect the rights and freedoms of data subjects.

In addition, the rights of access, rectification and cancellation referred to in articles 15 to 22 of Regulation (EU) 2016/679 are guaranteed, except for the limitations indicated in article 2-undecies of Legislative Decree 30 June 2003, n. 196.

The internal and external reports and the related documentation are kept for the time necessary for the processing of the report itself and, in any case, no later than 5 years from the date of communication of the final outcome of the reporting procedure, in compliance with the confidentiality obligations set out in European and national legislation on the protection of personal data.

WARNING

The report, both written and oral, can be made through the SIGNAL instant messaging APP, which guarantees the necessary levels of confidentiality and protection of the whistleblower, and the content.

The contact to whom to send the report is:

+ 39 344 0305340

The APP can be downloaded at the following link

Alternatively, the report can be sent in a closed envelope, without external identification of the sender and with the words “WHISTLEBLOWING REPORT”, to the address: FAEDA SPA – VIA G. PELLIZZARI 3 – 36050 MONTORSO VICENTINO (VI).