Raccortubi supports an ethical and safe working environment for all.

Information on the adaptation to new legislative indications on illegal conduct in the workplace (so-called WHISTLEBLOWING).

In compliance with internal and EU legislation, the company has set up an internal reporting system (so-called whistleblowing).

Through these channels anyone can, even completely anonymously, report to the company unlawful conduct by company personnel or in any case on the occasion of business activity.

The information received via this channel will be treated with attention, care and professionalism, as well as in accordance with the industry regulations and best practices.

It should be noted that the channels guarantee, if the whistleblower so wishes, full anonymity and, therefore, allow protection from any risk of retaliation.

Below is the analytical indication of the characteristics of the system, its method of operation, its purposes and, above all, the channels prepared.

1. SUBJECT OF THE REPORT

Legislative Decree no. 24 of 2023 establishes (in art. 2 letter a) the content of the breaches likely to be relevant within the scope of reporting regulations, including anonymous reporting (so-called whistleblowing), as follows:

“1. For the purposes of this decree, the following definitions apply:
a) “breaches”: conduct, actions or omissions that harm the public interest or the integrity of the public administration or private body and that consist of:
1) administrative, accounting, civil or criminal offences that do not fall within numbers 3), 4), 5) and 6);
2) relevant unlawful conduct pursuant to Legislative Decree no. 231 of 8 June 2001, or breaches of the organisation and management models provided for therein, which do not fall within numbers 3), 4), 5) and 6);
3) offences that fall within the scope of the European Union or national acts indicated in the annex to this decree or of the national acts that constitute implementation of the European Union acts indicated in the annex to Directive (EU) 2019/1937, although not indicated in the annex to this decree, 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; privacy protection and protection of personal data and security of networks and information systems;
4) actions or omissions affecting the financial interests of the Union referred to in article 325 of the Treaty on the Functioning of the European Union specified in the relevant secondary legislation of the European Union;
5) actions or omissions concerning the internal market, as referred to in article 26, paragraph 2, of the Treaty on the Functioning of the European Union, including breaches of European Union competition and State aid rules, as well as breaches concerning the internal market related to acts that contravene corporate tax rules or mechanisms, the purpose of which is to obtain a tax advantage that defeats the object or purpose of the applicable corporate tax legislation;
6) actions or conduct that defeat the object or purpose of the provisions of the acts of the Union in the areas indicated in numbers 3), 4) and 5)”.

2. REPORTING CHANNEL, EVEN ANONYMOUS, OF BREACHES

The company (in compliance with Legislative Decree no. 24 of 2023, in view of the ANAC guidelines on the subject and after consulting the trade union representatives pursuant to art. 4 of Legislative Decree no. 24 of 2023), has activated its own reporting channels that guarantee, also through the use of encryption tools, confidentiality of the identity of the reporting person, of the person involved and of the person in any case mentioned in the report, as well as the content of the report and of the related documentation.

Management of the reporting channel has been entrusted to the chairperson of the SB.

Reports may be made in writing, including by computer, or verbally using the telephone number indicated below.

Verbal internal reports are made through telephone lines or voice messaging systems or, at the request of the reporting person, through a direct meeting that will be set within a reasonable time.

As part of the management of the internal reporting channel, the following activities will be performed:

a) issuing to the reporting person notice of receipt of the report within seven days of the date of receipt;

b) holding, where necessary, of discussions with the reporting person, with the possibility of requesting additions from the latter, if necessary;

c) diligent follow-up will be given to the reports received;

d) reply to the report within three months from the date of the notice of receipt or, in the absence of such notice, within three months from the expiry of the seven-day period from submission of the report.

ACCESS LINK TO THE REPORTING PROGRAM:

https://whistleblowing.varhub.it/Azienda?code=RACCORTUBISPA

PHONE, SMS E WHATSAPP +393491220297

MAIL odv@raccortubi.com

It should also be remembered that the reporting person may make an external report.

This, however, is possible if at the time of submission of the report one of the following conditions applies:

a) there is no provision, within their working context, for mandatory activation of the internal reporting channel or this, even if mandatory, is not active or, even if activated, does not comply with the provisions of article 4;

b) the reporting person has already made an internal report pursuant to article 4 and the same has not been followed up on;

c) the reporting person has reasonable grounds to believe that if they made an internal report, it would not be effectively followed up on or that the same report could result in the risk of retaliation;

d) the reporting person has reasonable grounds to believe that the breach may constitute an imminent or obvious danger to the public interest.

ANAC REPORTING CHANNEL (for EXTERNAL REPORTS)

https://www.anticorruzione.it/-/whistleblowing

Download this policy here .