Whistleblowing

Internal reports pursuant to Legislative Decree 10 March 2023, n. 24 (so-called Whistleblowing)

We inform you that the company Fratelli Gionchetti Matelica F.g.m. S.r.l. (hereinafter “Company”) has established a channel for internal reporting in compliance with Legislative Decree 10 March 2023, n. 24 (hereinafter “Decree”), relating to reports of violations that harm the public interest or the integrity of the public administration or private entity, as identified in the articles. 2, paragraph 1, letter. a) and 3 paragraph 2 of the Decree.

Who can report?

The use of the internal channel is intended for the subjects indicated in the art. 3 of the Decree: in particular to subordinate and para-subordinate workers, self-employed workers and collaborators, freelancers, consultants, volunteers and trainees who work for the Company, shareholders and people with administrative, management, control, supervisory or representation functions, even if these functions are exercised on a purely practical basis, as well as, to the extent that they have become aware of violations in the context of working with the Company, also to public administration employees; of independent administrative authorities, public economic bodies, private law bodies subject to public control, in-house companies, public law bodies or public service concessionaires.

Reporting is permitted even if the aforementioned relationships have not started, if the information on the violations was acquired during the selection process or in other pre-contractual phases; during the probationary period and following the dissolution of the legal relationship if the information on the violations was acquired during the relationship itself.

How to report?

Internal reporting can be done via the following channels.

– Written channel: via written notification to be delivered

i) by registered mail to the attention of the Whistleblowing Office, to be sent to the Company’s headquarters in Via Marco Polo, n. 2, ZIP code 62024 Matelica (MC).

In any case, the reporter is invited to insert the report in two closed envelopes: the first with his/her identification data; the second with the subject of the report. Both envelopes must then be inserted into a third sealed envelope, without indication of the sender, which bears the words “Reserved for the Whistleblowing Office” on the outside. The envelope may be opened and handled exclusively by members of the Whistleblowing Office, in compliance with the confidentiality obligations established by the Decree.

– Oral channel: using the reserved telephone line no. 3347461733, managed directly by the company’s Whistleblowing Office. Using the same telephone number, the whistleblower may also request a specific direct meeting with the members of the Whistleblowing Office. The meeting will be held in a place that guarantees the confidentiality of the whistleblower, if necessary even outside the Company’s premises.

Oral reports (telephone or made in person) will be recorded, transcribed or documented in a detailed report by the Whistleblowing Office. The reporting party can verify, rectify and confirm the contents of the report and/or transcript with his signature.

The report, to be made in good faith, avoiding abusive or offensive tones, must indicate:
– name and surname, qualification and function/role of the responsible person, if known;
– circumstances of time and place of the event, together with any other element considered relevant for the purposes of the report;
– any subjects present at the site of the violation, who can potentially report on the incident;
– any attached documentation, which can confirm the validity of the reported fact;
– any private interests linked to the report;
– any other information that can facilitate the collection of evidence on what has been reported.

The report must also include the identity of the reporter and the contact details for the Whistleblowing Office.

How is the report handled?

The reports are received by a dedicated office (“Whistleblowing Office”) which proceeds with the relevant investigation in compliance with the confidentiality obligations established by the Decree.
Within 7 days of receipt, the Whistleblowing Office will give notice of receipt of the report and within the following 3 months will provide feedback on the outcome of the same.

Riservatezza e tutele

In application of the Decree, the right to confidentiality of the reporter, the facilitator and the people involved in the report is guaranteed.
Any form of retaliation against the whistleblower is prohibited, who can benefit from the protection measures referred to in the articles. 16 et seq. of the Decree, if the conditions exist.

The whistleblower who believes he or she has suffered retaliation as a result of the report may notify the National Anti-Corruption Authority (ANAC) via its institutional channels.

All processing of personal data is carried out in compliance with the legislation on the protection of personal data.

Riservatezza e tutele

Segnalazione esterna

The reporter can make an external report via the channel established and accessible on the ANAC website in the following cases:

– the internal reporting channel indicated in the Procedure is not active;
– the reporting party has already made a report to the channel indicated in the Procedure and it has not been followed up;
– the whistleblower has reasonable grounds to believe that, if he/she made an internal report through the channel provided for by this Procedure, the same would not be followed up or the report could lead to the risk of retaliation;
– the reporting party has reasonable grounds to believe that the violation to be reported may constitute an imminent or obvious danger to the public interest.

To use the external reporting channel or to resort to public disclosure, in the cases provided for by the Decree, please refer to the guidelines and the official ANAC website.
For further information, please consult the complete procedure and the privacy information attached to it, which can be consulted at the following links: https://gionchetti.com/it_it/