Whistleblowing

 

Whistleblowing

The Company, member of ADR Group, has implemented a whistleblowing management process, updated in accordance with Legislative Decree No. 24 of 10 March 2023 on the Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law and laying down provisions regarding the protection of persons who report breaches of national laws1.

 

The main elements of the whistleblowing management system are:

  • a Whistleblowing Team in charge for receiving and managing whistleblowings; the Whistleblowing Team is composed of the Heads of the following ADR functions: (i) Internal Audit (acting as Coordinator), (ii) Human Capital, Organization & Procurement, (iii) General Counsel & Compliance, (iv) Chief Financial Officer, (v) Risk Governance & Compliance2.
  • a dedicated reporting channel for receiving and managing whistleblowings.


The Whistleblowing Team is entrusted with activities related to receiving and managing whistleblowings.

To ensure the effectiveness of the reporting process and provide broad and indiscriminate access to all individuals specified in Section 1.3 of the Whistleblowing Policy who want to make a whistleblowing disclosure, the Company makes available an information technology platform, accessible by all Whistleblowers (Employees, Third Parties, etc.) that allows reports to be made in written and oral form.

Whistleblowings can also be made orally by calling the voice mailbox at +39 02/81480081, entering the code 4289 to identify the company, and following the instructions of the voicemail.

The confidentiality of reports is secured by tone and voice distortion systems. In addition to the above channels, reports can also be made through a direct meeting with the Whistleblowing Team or one or more of its members, at the request of the whistleblower.

Although anonymous whistleblowings are a feasible alternative, whistleblowers are encouraged to prefer nominative whistleblowings for the benefit of the speed and effectiveness of investigations, with confidentiality protections guaranteed as per the Whistleblowing Policy.

Retaliations believed to have been suffered can be reported to the National Anticorruption Authority (ANAC) through the appropriate channel activated and managed by ANAC.

For more details, please refer to the Whistleblowing Management Policy available on this webpage.

In accordance with Legislative Decree No. 24/2023 and the Whistleblowing Policy, the whistleblower will be notified of the receipt of the whistleblowing within 7 days and provided with feedback on the follow-up to the whistleblowing within 3 months.

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