INTERNAL REPORTING SYSTEM FOR VIOLATIONS (WHISTLEBLOWING)

Pursuant to Legislative Decree No. 24 of March 10, 2023, which implements Directive (EU) 2019/1937, Limolane S.r.l. has established a Whistleblowing system to protect individuals who report breaches of EU law and to introduce measures to safeguard those who report violations of national laws.

1. PURPOSE AND SCOPE OF THE REPORTING SYSTEM

The decree protects those who, in the course of their work, become aware of unlawful conduct or legal violations that may undermine the public interest or the integrity of public administration or private organizations.

According to the Decree, reportable violations (if discovered within the working relationship with the Company) include:

• Unlawful acts under Legislative Decree No. 231/2001 or violations of the Organization, Management, and Control Model adopted by the Company (Model 231), if not already included in other categories;
• Regulatory violations in specific areas such as: public procurement; financial services, markets and anti-money laundering; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food safety and animal health; public health; consumer protection; privacy and personal data protection; cybersecurity;
• Conduct that harms the financial interests of the EU;
• Violations that compromise the internal market, including anti-competitive practices or breaches intended to gain a tax advantage for the Company.

Personal complaints, disputes and grievances solely related to one’s own employment or collaboration relationship do not constitute valid whistleblowing reports.

1. AUTHORIZED PERSONS TO REPORT

The following are entitled to report any irregularities:

• Employees;
• Self-employed workers and individuals with collaborative relationships;
• Collaborators or workers of suppliers of goods or services or contractors;
• Freelance professionals and consultants;
• Volunteers and interns;
• Partners and individuals with administrative, management, control, supervisory, or representation roles (including de facto ones).

The protections provided also extend to: facilitators; colleagues or individuals working in the same context as the reporting person; and natural or legal persons connected to the reporting person.

1. HOW TO REPORT A VIOLATION

Reports can be submitted in writing or orally, via the dedicated online platform: https://limolane.segnalazioni.net/ 

Limolane S.r.l. has entrusted the management of the reporting channel to Attorney Riccardo Roscini Vitali, President of the Supervisory Body, a professional with proven experience in whistleblowing, in accordance with Article 4, paragraph 2, of Legislative Decree 24/2023.

3.1 Management of violations

The procedure involves:

• an acknowledgement of receipt within 7 days of the report;
• the opportunity to interact with the reporting party for any clarifications;
• a thorough examination of the report’s content;
• a response within three months, calculated from the confirmation of receipt or, failing that, from the end of the 7-day period.

3.2 Requirements of violations

To be effective, the report must include a detailed description of the facts and all the elements that make the validity of the reported violation plausible and verifiable.

3.3 Confidentiality and Protection of the Whistleblower

Pursuant to Legislative Decree no. 24/2023, the Company guarantees:

• complete confidentiality of the whistleblower’s identity, unless explicitly consented;
• protection against any form of retaliation or discrimination;
• compliance with Regulation (EU) 2016/679 (GDPR) regarding the processing of personal data.

Only expressly authorized persons, within the limits of the law, can access the data relating to the report.

3.4 Processing of Personal Data

All personal data and information provided through the reporting system is used exclusively to manage and investigate reports; it is processed in compliance with applicable regulations, including privacy. Further details are contained in the Privacy Policy available in the attachments section of this page.

3.5 Sanctions and Liability

Violation of the confidentiality obligation constitutes a disciplinary offense, without prejudice to further legal responsibilities.

If a report is found to be unfounded and was made with intent or gross negligence by an employee, disciplinary action may be considered.

For further information on how to file a report and the Company’s reporting procedure, please refer to the “Whistleblowing Policy.” For further legal references, please consult Legislative Decree No. 24/2023. 

1. ATTACHMENTS

CTA per download  “Policy Whistleblowing” (English version)

CTA per dowload Informativa Privacy Whistleblowing” (English version)

CTA Access the plaform (link: https://limolane.segnalazioni.net/)