Almeco Group
Almeco Group
Almeco Group
Policy
Whistleblowing
Reporting and Whistleblowing
ALMECO S.P.A., hereinafter the “Company,” implements, as a legal obligation, the institution of “Whistleblowing” in order to counter any unlawful phenomena in the work environment and, in particular, in order to provide specific protection for the person who wishes to report an unlawful act, hereinafter referred to as the “Whistleblower,” so that he or she may act without fear of suffering prejudicial consequences against him or her, under the D.Lgs. n. 24 enacted March 10, 2023, in implementation of the directive (EU) 2019/1937.
The reporting of misconduct can be done using the internal channel identified by the Company, i.e., through the special online platform “VarWhistle” made accessible by the Data Controller via the link below.
It is recommended that the platform be accessed through non-Processor devices and Internet connections, as data related to Internet access history, in this case to the Whistleblowing platform could be stored in the Internet browser available on the company device in use and/or in the company firewall/proxy server. The Company could access such data (only and exclusively Internet access history) directly or indirectly, through its system administrators, for the purposes of maintenance, technical support and IT security.
The management of the internal reporting channel is entrusted to the members of the Supervisory Board (SB), hereinafter referred to as the “Reporting Managers,” as individuals authorized by the Data Controller to learn about the reported unlawful facts in order to prepare any actions aimed at strengthening the measures to prevent unlawful acts and, identified in:
The Reporter will be able to select how to submit the report, proceeding to “anonymous report” or “signed report”.
In both cases, an alphanumeric code will be assigned at the end of the reporting process, which will allow the reporter to access the reporting monitoring interface, guaranteeing so-called “depersonalization,” i.e., future access to the platform without specific credentials that may even indirectly allow for identification.
The Company has implemented technical and organizational security measures aimed at ensuring the utmost confidentiality, integrity and availability of personal data and, therefore, the identity of the Whistleblower, the content of the report and the related documentation will be kept confidential at every stage of the handling of the report, so that the same may not suffer any discrimination or pressure, direct or indirect, as specifically provided for in the relevant regulations.
The platform, through internal communication channels, allows the Reporting Managers to interact with the Reporting Officer and report on the progress of the investigation, if initiated, guaranteeing, at all times, the confidentiality of the Reporting Officer’s identity.
The report must relate exclusively to misconduct governed by the attached 231 Whistleblowing Model and external regulations and may not, therefore, be used by the Whistleblower to send, for example, grievances of a personal nature pertaining to the discipline of the employment relationship.
The Whistleblower, in addition to the protection of the confidentiality of identity, is also protected against any retaliatory or discriminatory behavior, act or omission, even if only attempted or threatened, carried out because of the report.
It should be noted that the protections are not guaranteed when criminal liability of the Whistleblower is established for the crimes of defamation or slander or civil liability, for the same title, in cases of malice or gross negligence and that, in such cases, a disciplinary sanction may be imposed on the Whistleblower.
The reporter has the right to make use of the external channel made available by ANAC through the link below in the following cases: