Whistleblowing

WHISTLEBLOWING REPORTS

C.F.R. S.R.L. promotes an open corporate culture, based on ethics, transparency and responsibility, and inspired by the values that guide us: trust, integrity, courage, passion and inclusion.

For this reason, C.F.R. S.R.L. provides channels to report to the reporting manager information referring to C.F.R. S.R.L. personnel relating to violations of laws and regulations, of the Code of Ethics and Conduct, as well as of the system of rules and procedures in force in CFR S.R.L.. These channels are not available for commercial complaints or for disputes and requests related to personal interests.

Thanks to the active and responsible participation of employees and third parties, reporting any non-compliant behavior, the company is allowed to identify any irregularities and promptly adopt the necessary corrective measures, preventing any economic or reputational damage.

Who can report?

Anyone can send a report, even anonymously: employees, former employees, candidates for job positions, partners, customers, suppliers, consultants, collaborators, partners and, more generally, anyone with an interest in C.F.R. S.R.L. business activities.

The report must be adequately substantiated, i.e. it must contain sufficient details to allow the reported facts to be ascertained (e.g. elements that allow enable identification of the subjects involved, the context, place and time period of the reported facts and any supporting documentation).

Whoever receives a report, in any form (written or oral), must transmit it promptly, and in any case within 7 days of its receipt, via the aforementioned channels, giving simultaneous notice of the transmission to the person making the report (if known) and guaranteeing absolute confidentiality.

How reports are handled

Within 7 days of receipt, an acknowledgment of receipt of the report will be given and within 3 months of this notice, feedback will be provided on the follow-up that is given or intended to be given to the report.

Guarantee of confidentiality and protections

Legislative Decree 10 March 2023 n. 24 (implementation of European Directive 2019/1937 on Whistleblowing) introduced a unitary regulation of reporting channels and protections recognized for whistleblowers in the public and private sector.

The reporter, the facilitator and the people involved in the report are guaranteed absolute confidentiality. In the case of anonymous reports, it is not possible to trace the identity of the reporter.

Any form of personal or professional retaliation on account of the reporting activity is not permitted or tolerated.

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

To find out more, refer to the former-Article 13 Whistleblowing in the attachments.

Reports to the National Anti-Corruption Authority (ANAC) via external channel

In the event that after having made a report no acknowledgement of receipt and/or feedback on the action taken on the report is received, or you have reasonable grounds to believe (based on concrete circumstances and information that can actually be acquired) that the report internal investigation would not be effectively followed up or that it could lead to retaliation, or that the violation may constitute an imminent or obvious danger to the public interest, it is possible to send a report to ANAC via the IT platform.

The list of Third Sector entities that provide whistleblowers with support measures (information, assistance and consultancy free of charge) on reporting methods and protection from retaliation) is available on the ANAC website.