Whistleblowing
Premise
This Whistleblowing Procedure applies to Relatech SpA, which has adopted an internal reporting system compliant with Legislative Decree no. 24 of 10 March 2023.Legislation – Legislative Decree 24/2023
The discipline on whistleblowing, introduced pursuant to Directive (EU) 2019/1937 and implemented in Italy with Legislative Decree no. 24 of 10 March 2023, is aimed at facilitating the emergence of violations of national or European Union legislation learned in the workplace, ensuring the protection of those who make reports and protecting them from any resulting retaliation.What is whistleblowing?
The term "whistleblowing" refers to the reporting of information about violations falling within the scope of Legislative Decree 24/2023 that a person has learned of in the workplace. The whistleblowing system allows those identified by Legislative Decree 24/2023 to report such violations through dedicated channels that guarantee the confidentiality of the whistleblower's identity and protection from potential retaliation.What violations can be reported
The violations to be reported are those of national or European Union regulations that harm the public interest or the integrity of the public administration or private entity, of which the whistleblower has become aware in the work context (for example, environmental protection, public health, consumer protection, privacy and personal data protection, etc.).The following are expressly excluded from the scope of the legislation:
- disputes / claims / requests related to a personal interest of the whistleblower having as their object exclusively his/her individual work or employment relationship or inherent to his/her relationships with hierarchically superior figures;
- reports of violations already regulated by specific European Union or national provisions that provide for specific reporting channels;
- reports of national security violations.
Who can report
The following subjects can report:
- employees of the public administration and public economic bodies
- private sector subordinate workers
- self-employed workers
- workers/collaborators, freelancers and consultants
- paid and unpaid volunteers and interns
- shareholders and persons with administrative, management, control, supervisory or representative functions
The protections provided by Legislative Decree 24/2023 also apply when information on violations is acquired during the selection process, during the probationary period, or after the termination of the employment or collaboration relationship, in the cases provided for by the legislation.
How to report: internal channel
Reported violations can be reported through the INTERNAL channels set up by Relatech, which ensure, as required by law, the confidentiality of the whistleblower's identity and the information transmitted.
Pursuant to ANAC Guidelines no. 1/2025, email, whether ordinary (PEO) or certified (PEC), is generally not an appropriate tool for processing particularly sensitive data, especially when using accounts made available by the organization.
To this end, Relatech has set up the following secure INTERNAL channels:
Report in written form
Reporting in oral form
Recording is subject to the reporter's prior consent. If recording is not granted, the channel manager will prepare a detailed report of the report.
Furthermore, the whistleblower may request a direct meeting with the channel manager, to be held in a suitable location, even outside the organization, within a reasonable timeframe. The meeting is documented in minutes, which the reporting party has the right to verify, amend, and sign.
The management of Relatech's internal channels has been entrusted to’Supervisory Body of the company.
The platform made available by the provider (Ziveri Studio) allows you to submit anonymous reports. Although access requires registering an account, the identity of the reporter is not disclosed to the channel manager and can only be disclosed in the cases and ways provided by law or at the request of the competent authority. Anonymous reports will be considered if they are adequately detailed and allow for the necessary investigations.
In any case, the whistleblower is required to make the report in good faith and on the basis of information reasonably believed to be true at the time of the report.
How to report: external channel
- internal channels are not available or have not been activated;
- a report has already been made via the internal channel without any follow-up being given;
- the whistleblower fears that by using the internal channel, he or she would still suffer retaliation;
- the reporter believes that the violation poses an imminent danger to the public
Report Management
The channel manager issues the reporter an acknowledgement of receipt of the report within seven days from its receipt and provides feedback on the outcome of the same within three months from the date of the acknowledgement of receipt or, in its absence, from the expiry of the seven-day period, except in cases where the nature or complexity of the report requires additional time within the limits permitted by law.
Confidentiality
The identity of the whistleblower, the person involved (the so-called reported party), any persons mentioned in the report or the so-called facilitators, and the content of the report are processed in compliance with the confidentiality obligations set forth in Legislative Decree 24/2023 and the legislation on the protection of personal data.
Sanctions
Pursuant to art. 21 of Legislative Decree 24/2023, ANAC may apply administrative pecuniary sanctions from Euro 10,000 to Euro 50,000 against the responsible parties, among other things, in the event of the adoption of retaliatory measures, obstruction of reporting, violation of the confidentiality obligation, failure to establish the reporting channel, failure to adopt compliant procedures, or failure to manage the report.
If the responsibility of the whistleblower for the crimes of slander or defamation or his civil liability for intent or gross negligence is ascertained, even by a first instance ruling, the protections provided by Legislative Decree 24/2023 cease to apply and ANAC may apply an administrative pecuniary sanction from Euro 500 to Euro 2,500.