• WHAT YOU CAN REPORT
- Behavior, acts or omissions that harm the public interest or the integrity of the public administration or private entity and which consist of:
- Administrative, accounting, civil or criminal offences;
- Illegal conduct relevant pursuant to Legislative Decree 231/2001, or violations of the organization and management models provided therein;
- Offenses falling within the scope of application of European Union or national acts relating to the following sectors:
- Public procurement;
- Financial services, products and markets and prevention of money laundering and terrorist financing;
- Product safety and compliance;
- Transport safety;
- Environmental Protection;
- Radiation protection and nuclear safety;
- Food and feed safety and animal health and welfare;
- Public health;
- Consumer protection;
- Protection of privacy and protection of personal data and security of networks and information systems;
- Acts or omissions detrimental to the financial interests of the Union;
- Acts or omissions relating to the internal market;
- Acts or behavior that frustrate the object or purpose of the provisions set out in Union acts.
• WHAT MUST NOT BE THE SUBJECT OF A "WHISTLEBLOWING REPORT"
The following are excluded from the application of the legislation in question:
- Disputes, claims or requests linked to a personal interest of the reporting person or of the person who has filed a complaint with the judicial authority which relate exclusively to their individual work or public employment relationships, or inherent to their employment or of public employment with hierarchically superior figures (therefore, for example, reports regarding labor disputes and pre-litigation phases, discrimination between colleagues, interpersonal conflicts between the reporting person and another worker or with hierarchical superiors, reports relating to data processing carried out in the context of the individual employment relationship in the absence of harm to the public interest or the integrity of the public administration or private entity);
- Reports of violations where already regulated on a mandatory basis by the European Union or national acts indicated in part II of the annex to the decree or by the national ones which constitute the implementation of the European Union acts indicated in part II of the annex to the directive ( EU) 2019/1937, although not indicated in part II of the annex to the decree;
- Reports of violations relating to national security, as well as procurement relating to aspects of defense or national security, unless such aspects fall under relevant secondary legislation of the European Union.
• THE REPORTING CHANNELS
- Internal;
- External (managed by the A.N.A.C.);
- Public dissemination (via the press, electronic media or broadcast media capable of reaching a large number of people);
- Report to the judicial or accounting authority.
• CHOICE OF THE REPORTING CHANNEL
Reporters can use the external channel (ANAC) when:
- Within the work context, the mandatory activation of the internal reporting channel is not envisaged or this, even if mandatory, is not active or, even if activated, does not comply with what is required by law;
- The reporting person has already made an internal report and it has not been followed up on;
- The reporting person has reasonable grounds to believe that, if he/she made an internal report, it would not be followed up effectively or that the report itself could lead to a risk of retaliation;
- The reporting person has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest;
For further information in relation to the competences of ANAC, they are available by accessing the website of the aforementioned Authority: https://www.anticorruzione.it
• PLEASE NOTE:
The ANAC has provided for sanctions from €500 to €2,500 for whistleblowers, in the event that the criminal liability of the reporting person for crimes of defamation or slander is ascertained.
Before proceeding with the report, I confirm that I have read and understood the above legislation and I intend to proceed with the report. By flag
The external channel managed by ANAC is available by accessing the link: https://whistleblowing.anticorruzione.it/#/
(We inform you that, in the event of an external report, this will be managed by the ANAC in accordance with the "Regulation for the management of external reports and for the exercise of the sanctioning power of the ANAC in implementation of the legislative decree of 10 March 2023, n. 24. Resolution no. 301 of 12 July 2023").
