WHISTLEBLOWING REPORTS
Internal reports pursuant to Legislative Decree 24 of March 10, 2023
The company SABRY MAGLIERIA SRL a S.U. (hereinafter referred to as the “Company”) has established an internal reporting channel for the receipt and management of reports of wrongdoing, in compliance with Legislative Decree no. 24 of March 10, 2023 (the “Decree”), concerning the protection of persons who report breaches of Union and national laws.
Who can report
The internal reporting channel may be used by the individuals identified in Article 3 of the Decree, including:
• employees, self-employed workers, or collaborators;
• freelancers, consultants, volunteers, interns (even unpaid);
• shareholders and individuals with administrative, management, supervisory, or representative functions, even if de facto;
• individuals working for public or private entities that have relations with the Company.
The protections also apply to individuals who report:
• during recruitment or other pre-contractual phases;
• during the probationary period;
• after the end of the relationship, if the information was acquired during its term..
How to file an internal report
Reports can be submitted through the following channels:
1. Written channel (off-line / on-line)
• By registered mail with return receipt addressed to the “Whistleblowing Office” at the law office of Avv. ANGELO GIARDINI located in Via Dell’Industria 304, 62014, Corridonia (Mc).
• It is recommended to use a double-envelope system:
o the first envelope should contain the reporter’s identifying information;
o the second should contain the content of the report;
o both should be placed in a third sealed envelope labeled “Confidential – To the Whistleblowing Office”.
2. Oral channel
• By calling the dedicated telephone line: +393282179079 with the option to leave a voicemail message;
• By requesting a meeting with the Whistleblowing Office representatives.
The meeting will be held in a location that ensures the reporter’s confidentiality, even off-site if necessary.
Oral reports will be documented via transcription or recording (with consent). The reporter may review, amend, and sign the final version of the record.
Contents of the report
Reports, which must be made in good faith, should preferably include:
• identification of the alleged offender (if known);
• description of the events (place, date, circumstances);
• names of any witnesses;
• supporting documentation;
• any potential conflicts of interest;
• reporter’s contact details for confidential follow-up.
Handling of the report
Reports are handled by the Whistleblowing Office, which ensures impartial and confidential processing.
The office will:
• acknowledge receipt within 7 days;
• provide a follow-up within 3 months.
Confidentiality and protection
The confidentiality of the reporter, the facilitator, and the persons involved is guaranteed under the Decree.
Any form of retaliation is strictly prohibited. The reporter may contact ANAC if they believe they have been subject to retaliation.
External reporting
An external report may be submitted via the National Anti-Corruption Authority (ANAC) platform in the following cases:
• the internal channel is inactive or non-compliant;
• the report was not followed up;
• there is a risk of retaliation or the internal channel is deemed ineffective;
• there is an imminent or obvious threat to the public interest.
For conditions, procedures, and cases of public disclosure, please refer to the ANAC guidelines and the official website: www.anticorruzione.it
Privacy
The processing of personal data is carried out in compliance with Regulation (EU) 2016/679 and Legislative Decree 196/2003, as amended.
For further details, please refer to the full procedure and related privacy policies.
