The value of transparency
The Company fosters an open corporate culture, marked by ethics, transparency and responsibility, and inspired by its corporate values. For this reason, it asks its staff, e.g. directors, managers, supervisory bodies, employees and other collaborators, and all its partners, to operate in full compliance with the Laws and Regulations, Code of Ethics and Human Rights.
The Company strongly encourages its stakeholders to report any improper, dishonest or illegal activity – potential, highly probable or already committed – as well as conduct that may cause damage or harm, including to the Company’s image (so-called whistleblowing).
To this end, the Company has implemented specific rules and a management process in compliance with the ‘Whistleblowing’ Legislative Decree no. 24 of 2023 to provide potential whistleblowers with secure channels and guarantee the confidentiality of their identity, the information stated in the report, as well as their protection from possible retaliation.
Reports concerning the whistleblower’s personal interests, complaints or grievances of a personal or commercial nature, claims or demands that fall within the scope of the employment agreements are excluded from the scope of the legislation. Should a report be unfounded, made in bad faith or with gross negligence, the Company reserves the right to act in defence of its interests and to protect the offended parties.
Report Handling
To manage whistleblowing reports, the Company has appointed a Committee of external experts in whistleblowing legislation, organisational models pursuant to Legislative Decree no. 231 of 2001 and management systems, EU law and industrial relations as well as labour law. Such Committee is autonomous, impartial and independent with respect to the processes that could be the subject matter of a report. The Company encourages whistleblowers to give priority to identified and non-anonymous reports, to streamline investigations and make them more effective. However, anonymous reports are also accepted, provided they are fully substantiated.
In ensure the effectiveness of the reporting process and provide broad and indiscriminate access to all those who wish to make a report, a number of alternative communication channels have made available, such as:
- Registered mail with acknowledgement of receipt to be addressed to: WHISTLEBLOWING COMMITTEE of Confindustria CNVV – STRICTLY CONFIDENTIAL – C.so Cavallotti, 25 28100 NOVARA (NO), using the double envelope system as per point 5 of the Whistleblowing Procedure
- Oral report to the Expert Committee or one of its members (upon request to whistleblowing@cnvv.it)
Functionality monitoring of such communication channels is ensured by the Whistleblowing Committee, to be contacted should any malfunctioning arise.