Whistleblowing reports
(D.LGS. 24/2023)
BETACOM S.R.L. has always been particularly attentive to the prevention of risks that could compromise the responsible and sustainable management of its functions.
BETACOM S.R.L, in compliance with the provisions of legislative decree 10 March 2023, n. 24, implements in Italy Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, concerning the protection of persons who report breaches of Union law and in line with international best practices, has adopted the “whistleblowing” procedure for handling reports.
At the same time, we have implemented this IT portal to guarantee the confidentiality of the whistleblower's identity in report management activities by entrusting the service to Lumina Fiduciaria SPA , a Trust Company operating under the authorization obtained from the Ministry of Economic Development (MISE) as established by Law 1966/39.
Who can make a “whistleblowing” report?
The decree defines "whistleblower" as the natural person who reports or publicises information about violations acquired within their work context.
The "whistleblower" subjects protected by the decree are:
employees of public administrations, independent administrative authorities, public economic entities, private law entities controlled by public administration, in-house companies, bodies governed by public law or public service concessionaires;
employed workers in the private sector, including workers whose employment relationship is regulated by legislative decree 15 June 2015, n. 81, or by article 54-bis of decree-law 24 April 2017, n. 50, converted, with amendments, by law 21 June 2017, n. 96;
self-employed workers, including those referred to in Chapter I of Law 22 May 2017, n. 81, as well as holders of a collaboration relationship referred to in article 409 of the civil procedure code and article 2 of legislative decree n. 81 of 2015, who carry out their work activity in public or private sector entities;
workers or collaborators who carry out their work activity in public or private sector entities that provide goods or services or execute works on behalf of third parties;
freelancers and consultants who provide their services in public or private sector entities;
volunteers and trainees, paid and unpaid, who provide their services in public or private sector entities;
shareholders and persons with administrative, management, control, supervisory or representative functions, even if such functions are exercised on a purely de facto basis, in public or private sector entities.
The protections provided for the whistleblower also apply to:
so-called facilitators (those who assist the worker in the reporting process);
persons within the same work context as the whistleblower or the person who filed a complaint with the judicial or accounting authority or made a public disclosure, who are linked to them by a stable emotional or family bond up to the fourth degree;
colleagues of the whistleblower or the person who filed a complaint with the judicial or accounting authority or made a public disclosure, who work in the same work context and have a regular and current relationship with said person;
entities owned by the whistleblower or the person who filed a complaint with the judicial or accounting authority or made a public disclosure, or for whom the same persons work, as well as entities operating in the same work context as the aforementioned persons.
What protections are guaranteed to the whistleblower?
Whistleblowers cannot suffer any retaliation; the decree indicates certain circumstances which, if they fall within the definition of retaliation, and establishes measures and conditions for the protection of whistleblowers.
Protection also applies:
if the legal relationship has not yet started (selection and pre-contractual phases);
during the probationary period;
after the termination of the relationship (if the information was acquired during the relationship).
What can be reported?
The decree defines "report" as the written or oral communication of information on "violations", defined as behaviors, acts, or omissions that harm the public interest or the integrity of the public administration or private entity and consist of:
Administrative, accounting, civil or criminal offenses;
unlawful conduct relevant under Legislative Decree 231/2001, or violation of organization and management models;
offenses falling within the scope of application of the European Union or national acts indicated in the annex to the decree or national acts constituting implementation of the European Union acts indicated in the annex to Directive 2019/1937, even if not indicated in the annex to the decree, regarding the following sectors: public procurement; financial services, products and markets; prevention of money laundering and terrorist financing; safety of food, animal feed, animal health and welfare; product safety and compliance; transport safety; public health; protection of privacy and personal data; environmental protection; radiation protection and nuclear safety; consumer protection; security of network and information systems
acts or omissions affecting the financial interests of the European Union (Article 325 TFEU);
acts and omissions relating (Article 26, paragraph 2 TFEU) to the free movement of goods, persons, services and capital in the internal market, including violations of European Union rules on Competition, State Aid, Corporate Taxation.
acts or behaviors that defeat the object and purpose of the EU provisions referred to in points 3, 4 and 5.
The decree defines "retaliation" as any behavior, act, or omission, even if only attempted or threatened, carried out as a result of the report, the complaint to the judicial or accounting authority or public disclosure, and which causes or may cause, directly or indirectly, unjustified harm to the whistleblower or the person who filed the complaint.
Privacy
All personal data will be processed in accordance with the current Privacy Regulations (meaning EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), Legislative Decree n. 196/2003, Legislative Decree n.101/2018 as well as any other personal data protection legislation applicable in Italy, including provisions of the Garante), in full respect of fundamental rights and freedoms, with particular regard to the confidentiality of the identity of the data subjects and the security of processing.
For further details
Download the Lumina Fiduciaria Privacy PDF
How to make a report
Reports can be made using the specific web channel available at www.WB24.it, which allows both written and voice reports. After initial registration, the portal allows you to upload your report and subsequently monitor the status of the case.
BETACOM S.R.L. has always been particularly attentive to the prevention of risks that could compromise the responsible and sustainable management of its functions.
BETACOM S.R.L, in compliance with the provisions of legislative decree 10 March 2023, n. 24, implements in Italy Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, concerning the protection of persons who report breaches of Union law and in line with international best practices, has adopted the “whistleblowing” procedure for handling reports.
At the same time, we have implemented this IT portal to guarantee the confidentiality of the whistleblower's identity in report management activities by entrusting the service to Lumina Fiduciaria SPA , a Trust Company operating under the authorization obtained from the Ministry of Economic Development (MISE) as established by Law 1966/39.
Who can make a “whistleblowing” report?
The decree defines "whistleblower" as the natural person who reports or publicises information about violations acquired within their work context.
The "whistleblower" subjects protected by the decree are:
employees of public administrations, independent administrative authorities, public economic entities, private law entities controlled by public administration, in-house companies, bodies governed by public law or public service concessionaires;
employed workers in the private sector, including workers whose employment relationship is regulated by legislative decree 15 June 2015, n. 81, or by article 54-bis of decree-law 24 April 2017, n. 50, converted, with amendments, by law 21 June 2017, n. 96;
self-employed workers, including those referred to in Chapter I of Law 22 May 2017, n. 81, as well as holders of a collaboration relationship referred to in article 409 of the civil procedure code and article 2 of legislative decree n. 81 of 2015, who carry out their work activity in public or private sector entities;
workers or collaborators who carry out their work activity in public or private sector entities that provide goods or services or execute works on behalf of third parties;
freelancers and consultants who provide their services in public or private sector entities;
volunteers and trainees, paid and unpaid, who provide their services in public or private sector entities;
shareholders and persons with administrative, management, control, supervisory or representative functions, even if such functions are exercised on a purely de facto basis, in public or private sector entities.
The protections provided for the whistleblower also apply to:
so-called facilitators (those who assist the worker in the reporting process);
persons within the same work context as the whistleblower or the person who filed a complaint with the judicial or accounting authority or made a public disclosure, who are linked to them by a stable emotional or family bond up to the fourth degree;
colleagues of the whistleblower or the person who filed a complaint with the judicial or accounting authority or made a public disclosure, who work in the same work context and have a regular and current relationship with said person;
entities owned by the whistleblower or the person who filed a complaint with the judicial or accounting authority or made a public disclosure, or for whom the same persons work, as well as entities operating in the same work context as the aforementioned persons.
What protections are guaranteed to the whistleblower?
Whistleblowers cannot suffer any retaliation; the decree indicates certain circumstances which, if they fall within the definition of retaliation, and establishes measures and conditions for the protection of whistleblowers.
Protection also applies:
if the legal relationship has not yet started (selection and pre-contractual phases);
during the probationary period;
after the termination of the relationship (if the information was acquired during the relationship).
What can be reported?
The decree defines "report" as the written or oral communication of information on "violations", defined as behaviors, acts, or omissions that harm the public interest or the integrity of the public administration or private entity and consist of:
Administrative, accounting, civil or criminal offenses;
unlawful conduct relevant under Legislative Decree 231/2001, or violation of organization and management models;
offenses falling within the scope of application of the European Union or national acts indicated in the annex to the decree or national acts constituting implementation of the European Union acts indicated in the annex to Directive 2019/1937, even if not indicated in the annex to the decree, regarding the following sectors: public procurement; financial services, products and markets; prevention of money laundering and terrorist financing; safety of food, animal feed, animal health and welfare; product safety and compliance; transport safety; public health; protection of privacy and personal data; environmental protection; radiation protection and nuclear safety; consumer protection; security of network and information systems
acts or omissions affecting the financial interests of the European Union (Article 325 TFEU);
acts and omissions relating (Article 26, paragraph 2 TFEU) to the free movement of goods, persons, services and capital in the internal market, including violations of European Union rules on Competition, State Aid, Corporate Taxation.
acts or behaviors that defeat the object and purpose of the EU provisions referred to in points 3, 4 and 5.
The decree defines "retaliation" as any behavior, act, or omission, even if only attempted or threatened, carried out as a result of the report, the complaint to the judicial or accounting authority or public disclosure, and which causes or may cause, directly or indirectly, unjustified harm to the whistleblower or the person who filed the complaint.
Privacy
All personal data will be processed in accordance with the current Privacy Regulations (meaning EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), Legislative Decree n. 196/2003, Legislative Decree n.101/2018 as well as any other personal data protection legislation applicable in Italy, including provisions of the Garante), in full respect of fundamental rights and freedoms, with particular regard to the confidentiality of the identity of the data subjects and the security of processing.
For further details
Download the Lumina Fiduciaria Privacy PDF
How to make a report
Reports can be made using the specific web channel available at www.WB24.it, which allows both written and voice reports. After initial registration, the portal allows you to upload your report and subsequently monitor the status of the case.
BETACOM S.R.L. has always been particularly attentive to the prevention of risks that could compromise the responsible and sustainable management of its functions.
BETACOM S.R.L, in compliance with the provisions of legislative decree 10 March 2023, n. 24, implements in Italy Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, concerning the protection of persons who report breaches of Union law and in line with international best practices, has adopted the “whistleblowing” procedure for handling reports.
At the same time, we have implemented this IT portal to guarantee the confidentiality of the whistleblower's identity in report management activities by entrusting the service to Lumina Fiduciaria SPA , a Trust Company operating under the authorization obtained from the Ministry of Economic Development (MISE) as established by Law 1966/39.
Who can make a “whistleblowing” report?
The decree defines "whistleblower" as the natural person who reports or publicises information about violations acquired within their work context.
The "whistleblower" subjects protected by the decree are:
employees of public administrations, independent administrative authorities, public economic entities, private law entities controlled by public administration, in-house companies, bodies governed by public law or public service concessionaires;
employed workers in the private sector, including workers whose employment relationship is regulated by legislative decree 15 June 2015, n. 81, or by article 54-bis of decree-law 24 April 2017, n. 50, converted, with amendments, by law 21 June 2017, n. 96;
self-employed workers, including those referred to in Chapter I of Law 22 May 2017, n. 81, as well as holders of a collaboration relationship referred to in article 409 of the civil procedure code and article 2 of legislative decree n. 81 of 2015, who carry out their work activity in public or private sector entities;
workers or collaborators who carry out their work activity in public or private sector entities that provide goods or services or execute works on behalf of third parties;
freelancers and consultants who provide their services in public or private sector entities;
volunteers and trainees, paid and unpaid, who provide their services in public or private sector entities;
shareholders and persons with administrative, management, control, supervisory or representative functions, even if such functions are exercised on a purely de facto basis, in public or private sector entities.
The protections provided for the whistleblower also apply to:
so-called facilitators (those who assist the worker in the reporting process);
persons within the same work context as the whistleblower or the person who filed a complaint with the judicial or accounting authority or made a public disclosure, who are linked to them by a stable emotional or family bond up to the fourth degree;
colleagues of the whistleblower or the person who filed a complaint with the judicial or accounting authority or made a public disclosure, who work in the same work context and have a regular and current relationship with said person;
entities owned by the whistleblower or the person who filed a complaint with the judicial or accounting authority or made a public disclosure, or for whom the same persons work, as well as entities operating in the same work context as the aforementioned persons.
What protections are guaranteed to the whistleblower?
Whistleblowers cannot suffer any retaliation; the decree indicates certain circumstances which, if they fall within the definition of retaliation, and establishes measures and conditions for the protection of whistleblowers.
Protection also applies:
if the legal relationship has not yet started (selection and pre-contractual phases);
during the probationary period;
after the termination of the relationship (if the information was acquired during the relationship).
What can be reported?
The decree defines "report" as the written or oral communication of information on "violations", defined as behaviors, acts, or omissions that harm the public interest or the integrity of the public administration or private entity and consist of:
Administrative, accounting, civil or criminal offenses;
unlawful conduct relevant under Legislative Decree 231/2001, or violation of organization and management models;
offenses falling within the scope of application of the European Union or national acts indicated in the annex to the decree or national acts constituting implementation of the European Union acts indicated in the annex to Directive 2019/1937, even if not indicated in the annex to the decree, regarding the following sectors: public procurement; financial services, products and markets; prevention of money laundering and terrorist financing; safety of food, animal feed, animal health and welfare; product safety and compliance; transport safety; public health; protection of privacy and personal data; environmental protection; radiation protection and nuclear safety; consumer protection; security of network and information systems
acts or omissions affecting the financial interests of the European Union (Article 325 TFEU);
acts and omissions relating (Article 26, paragraph 2 TFEU) to the free movement of goods, persons, services and capital in the internal market, including violations of European Union rules on Competition, State Aid, Corporate Taxation.
acts or behaviors that defeat the object and purpose of the EU provisions referred to in points 3, 4 and 5.
The decree defines "retaliation" as any behavior, act, or omission, even if only attempted or threatened, carried out as a result of the report, the complaint to the judicial or accounting authority or public disclosure, and which causes or may cause, directly or indirectly, unjustified harm to the whistleblower or the person who filed the complaint.
Privacy
All personal data will be processed in accordance with the current Privacy Regulations (meaning EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), Legislative Decree n. 196/2003, Legislative Decree n.101/2018 as well as any other personal data protection legislation applicable in Italy, including provisions of the Garante), in full respect of fundamental rights and freedoms, with particular regard to the confidentiality of the identity of the data subjects and the security of processing.
For further details
Download the Lumina Fiduciaria Privacy PDF
How to make a report
Reports can be made using the specific web channel available at www.WB24.it, which allows both written and voice reports. After initial registration, the portal allows you to upload your report and subsequently monitor the status of the case.
BETACOM S.R.L. has always been particularly attentive to the prevention of risks that could compromise the responsible and sustainable management of its functions.
BETACOM S.R.L, in compliance with the provisions of legislative decree 10 March 2023, n. 24, implements in Italy Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, concerning the protection of persons who report breaches of Union law and in line with international best practices, has adopted the “whistleblowing” procedure for handling reports.
At the same time, we have implemented this IT portal to guarantee the confidentiality of the whistleblower's identity in report management activities by entrusting the service to Lumina Fiduciaria SPA , a Trust Company operating under the authorization obtained from the Ministry of Economic Development (MISE) as established by Law 1966/39.
Who can make a “whistleblowing” report?
The decree defines "whistleblower" as the natural person who reports or publicises information about violations acquired within their work context.
The "whistleblower" subjects protected by the decree are:
employees of public administrations, independent administrative authorities, public economic entities, private law entities controlled by public administration, in-house companies, bodies governed by public law or public service concessionaires;
employed workers in the private sector, including workers whose employment relationship is regulated by legislative decree 15 June 2015, n. 81, or by article 54-bis of decree-law 24 April 2017, n. 50, converted, with amendments, by law 21 June 2017, n. 96;
self-employed workers, including those referred to in Chapter I of Law 22 May 2017, n. 81, as well as holders of a collaboration relationship referred to in article 409 of the civil procedure code and article 2 of legislative decree n. 81 of 2015, who carry out their work activity in public or private sector entities;
workers or collaborators who carry out their work activity in public or private sector entities that provide goods or services or execute works on behalf of third parties;
freelancers and consultants who provide their services in public or private sector entities;
volunteers and trainees, paid and unpaid, who provide their services in public or private sector entities;
shareholders and persons with administrative, management, control, supervisory or representative functions, even if such functions are exercised on a purely de facto basis, in public or private sector entities.
The protections provided for the whistleblower also apply to:
so-called facilitators (those who assist the worker in the reporting process);
persons within the same work context as the whistleblower or the person who filed a complaint with the judicial or accounting authority or made a public disclosure, who are linked to them by a stable emotional or family bond up to the fourth degree;
colleagues of the whistleblower or the person who filed a complaint with the judicial or accounting authority or made a public disclosure, who work in the same work context and have a regular and current relationship with said person;
entities owned by the whistleblower or the person who filed a complaint with the judicial or accounting authority or made a public disclosure, or for whom the same persons work, as well as entities operating in the same work context as the aforementioned persons.
What protections are guaranteed to the whistleblower?
Whistleblowers cannot suffer any retaliation; the decree indicates certain circumstances which, if they fall within the definition of retaliation, and establishes measures and conditions for the protection of whistleblowers.
Protection also applies:
if the legal relationship has not yet started (selection and pre-contractual phases);
during the probationary period;
after the termination of the relationship (if the information was acquired during the relationship).
What can be reported?
The decree defines "report" as the written or oral communication of information on "violations", defined as behaviors, acts, or omissions that harm the public interest or the integrity of the public administration or private entity and consist of:
Administrative, accounting, civil or criminal offenses;
unlawful conduct relevant under Legislative Decree 231/2001, or violation of organization and management models;
offenses falling within the scope of application of the European Union or national acts indicated in the annex to the decree or national acts constituting implementation of the European Union acts indicated in the annex to Directive 2019/1937, even if not indicated in the annex to the decree, regarding the following sectors: public procurement; financial services, products and markets; prevention of money laundering and terrorist financing; safety of food, animal feed, animal health and welfare; product safety and compliance; transport safety; public health; protection of privacy and personal data; environmental protection; radiation protection and nuclear safety; consumer protection; security of network and information systems
acts or omissions affecting the financial interests of the European Union (Article 325 TFEU);
acts and omissions relating (Article 26, paragraph 2 TFEU) to the free movement of goods, persons, services and capital in the internal market, including violations of European Union rules on Competition, State Aid, Corporate Taxation.
acts or behaviors that defeat the object and purpose of the EU provisions referred to in points 3, 4 and 5.
The decree defines "retaliation" as any behavior, act, or omission, even if only attempted or threatened, carried out as a result of the report, the complaint to the judicial or accounting authority or public disclosure, and which causes or may cause, directly or indirectly, unjustified harm to the whistleblower or the person who filed the complaint.
Privacy
All personal data will be processed in accordance with the current Privacy Regulations (meaning EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), Legislative Decree n. 196/2003, Legislative Decree n.101/2018 as well as any other personal data protection legislation applicable in Italy, including provisions of the Garante), in full respect of fundamental rights and freedoms, with particular regard to the confidentiality of the identity of the data subjects and the security of processing.
For further details
Download the Lumina Fiduciaria Privacy PDF
How to make a report
Reports can be made using the specific web channel available at www.WB24.it, which allows both written and voice reports. After initial registration, the portal allows you to upload your report and subsequently monitor the status of the case.
What happens if I make the report using other channels?
The "whistleblowing" regulation recognizes the whistleblower's right to protection regardless of the means of communication used, explicitly favoring the IT channel. The company has set up the IT reporting channel in order to guarantee the anonymity of the whistleblower. Any reports made to entities other than Lumina Fiduciaria or through other channels (e.g., email, PEC, regular mail, telephone) are by their nature not suitable for guaranteeing the whistleblower's anonymity. All parties involved will in any case handle the report with the utmost care and in accordance with the provisions of the regulations. Any reports made to entities not designated and therefore not trained to manage whistleblowing reports could compromise anonymity and make it impossible for the company to guarantee the whistleblower's rights.
How is the whistleblower's anonymity guaranteed?
The reporting process is managed on a complete outsourcing basis by Lumina Fiduciaria SPA, a trust company operating under authorization obtained from the Ministry of Economic Development (MISE) as established by Law 1966/39.
Lumina Fiduciaria collects reports through the dedicated portal www.WB24.it which, through encryption technology, separates the personal details of the whistleblower from the report itself.
The report will therefore be processed in a completely anonymous manner in accordance with the "whistleblowing" regulation, while the whistleblower's personal details will be stored and kept secret by the trust company and only accessible in the specific cases provided for by law.
What happens after the report is made?
Within seven days from the date of receipt, Lumina Fiduciaria issues an "acknowledgement of receipt". The anonymous "report" is immediately transmitted to the designated office of the reported company. In this specific case, the report is transmitted to the following subjects:
Chairman of the Board of Directors
Chief Executive Officer
Chairman of the Board of Statutory Auditors
Supervisory Body (ODV 231)
Whistleblowing management committee
* depending on the organizational model of the company subject to the report
Within the mandatory period of 3 months from the acknowledgement of receipt, the whistleblower must peremptorily receive the outcome of the report. The whistleblower will be able to consult the "acknowledgement of receipt", the outcome of the report, and any communications from the company by accessing the website anonymously at www.WB24.it
What can the whistleblower do if the reported company does not follow up on my report?
The "whistleblowing" regulation allows the whistleblower to make an external report directly to ANAC (National Anti-Corruption Authority) https://www.anticorruzione.it/-/whistleblowing in the event that:
After 3 months have passed since the report was made through the dedicated internal channel, the company has not provided any feedback.
The internal channel is not active or, if active, does not comply with the provisions of the decree.
the whistleblower has reasonable grounds to believe, based on concrete attached circumstances and information actually obtainable, and therefore not on mere rumor, that if they made an internal report:
it would not be effectively followed up. This occurs when, for example, the ultimate manager in the work context is involved in the breach, there is a risk that the breach or related evidence may be concealed or destroyed, the effectiveness of investigations by competent authorities might otherwise be compromised, or because it is believed that ANAC would be better suited to address the specific breach, particularly in matters within its competence;
this could lead to the risk of retaliation (for example, as a result of breaching the obligation to maintain the confidentiality of the whistleblower's identity).
the whistleblower has reasonable grounds to believe that the breach may constitute an imminent or manifest danger to the public interest. Consider, for example, cases where the breach requires urgent intervention to safeguard public health and safety or to protect the environment.
The "whistleblowing" regulation also allows the whistleblower to make a public disclosure.
Through public disclosure, information on breaches is made public through the press, electronic media, or otherwise through dissemination means capable of reaching a large number of people. The legislator naturally takes into account the evolution of mass media, including social networks and new communication channels (for example, Facebook, Twitter, YouTube, Instagram), which constitute a rapid and interactive tool for transmitting and conveying information and exchanges between networks of people and organizations. The public disclosure of breaches must occur in compliance with the conditions set by the legislator in order for the person making it to benefit from the protections recognized by the decree.
Therefore, protection will be granted if one of the following conditions is met at the time of disclosure:
an internal report, to which the administration/entity has not responded regarding the measures planned or adopted to follow up on the report within the set terms
the person has already made an external report directly to ANAC which, however, did not provide feedback to the whistleblower regarding the measures planned or adopted to follow up on the report within a reasonable time (three months or, if justified and motivated reasons exist, six months from the date of the acknowledgment of receipt of the external report or, in the absence of such acknowledgment, from the expiry of seven days from receipt)
the person directly makes a public disclosure because, based on reasonable and well-founded grounds in light of the circumstances of the specific case, they believe that the breach may represent an imminent or manifest danger to the public interest. Consider, for example, an emergency situation or the risk of irreversible damage, including to the physical safety of one or more people, which requires the breach to be promptly disclosed and widely publicized to prevent its effects;
the person directly makes a public disclosure because, based on reasonable and well-founded grounds in light of the circumstances of the specific case, they believe that the external report may entail the risk of retaliation or may not be effectively followed up because, for example, they fear that evidence may be concealed or destroyed or that the recipient of the report may be in collusion with the author of the breach or involved in the breach itself. Consider, by way of example, the case where the person receiving the report of a breach, colluding with the person involved in the breach itself, proceeds to archive said report in the absence of grounds.
What happens if I make the report using other channels?
The "whistleblowing" regulation recognizes the whistleblower's right to protection regardless of the means of communication used, explicitly favoring the IT channel. The company has set up the IT reporting channel in order to guarantee the anonymity of the whistleblower. Any reports made to entities other than Lumina Fiduciaria or through other channels (e.g., email, PEC, regular mail, telephone) are by their nature not suitable for guaranteeing the whistleblower's anonymity. All parties involved will in any case handle the report with the utmost care and in accordance with the provisions of the regulations. Any reports made to entities not designated and therefore not trained to manage whistleblowing reports could compromise anonymity and make it impossible for the company to guarantee the whistleblower's rights.
How is the whistleblower's anonymity guaranteed?
The reporting process is managed on a complete outsourcing basis by Lumina Fiduciaria SPA, a trust company operating under authorization obtained from the Ministry of Economic Development (MISE) as established by Law 1966/39.
Lumina Fiduciaria collects reports through the dedicated portal www.WB24.it which, through encryption technology, separates the personal details of the whistleblower from the report itself.
The report will therefore be processed in a completely anonymous manner in accordance with the "whistleblowing" regulation, while the whistleblower's personal details will be stored and kept secret by the trust company and only accessible in the specific cases provided for by law.
What happens after the report is made?
Within seven days from the date of receipt, Lumina Fiduciaria issues an "acknowledgement of receipt". The anonymous "report" is immediately transmitted to the designated office of the reported company. In this specific case, the report is transmitted to the following subjects:
Chairman of the Board of Directors
Chief Executive Officer
Chairman of the Board of Statutory Auditors
Supervisory Body (ODV 231)
Whistleblowing management committee
* depending on the organizational model of the company subject to the report
Within the mandatory period of 3 months from the acknowledgement of receipt, the whistleblower must peremptorily receive the outcome of the report. The whistleblower will be able to consult the "acknowledgement of receipt", the outcome of the report, and any communications from the company by accessing the website anonymously at www.WB24.it
What can the whistleblower do if the reported company does not follow up on my report?
The "whistleblowing" regulation allows the whistleblower to make an external report directly to ANAC (National Anti-Corruption Authority) https://www.anticorruzione.it/-/whistleblowing in the event that:
After 3 months have passed since the report was made through the dedicated internal channel, the company has not provided any feedback.
The internal channel is not active or, if active, does not comply with the provisions of the decree.
the whistleblower has reasonable grounds to believe, based on concrete attached circumstances and information actually obtainable, and therefore not on mere rumor, that if they made an internal report:
it would not be effectively followed up. This occurs when, for example, the ultimate manager in the work context is involved in the breach, there is a risk that the breach or related evidence may be concealed or destroyed, the effectiveness of investigations by competent authorities might otherwise be compromised, or because it is believed that ANAC would be better suited to address the specific breach, particularly in matters within its competence;
this could lead to the risk of retaliation (for example, as a result of breaching the obligation to maintain the confidentiality of the whistleblower's identity).
the whistleblower has reasonable grounds to believe that the breach may constitute an imminent or manifest danger to the public interest. Consider, for example, cases where the breach requires urgent intervention to safeguard public health and safety or to protect the environment.
The "whistleblowing" regulation also allows the whistleblower to make a public disclosure.
Through public disclosure, information on breaches is made public through the press, electronic media, or otherwise through dissemination means capable of reaching a large number of people. The legislator naturally takes into account the evolution of mass media, including social networks and new communication channels (for example, Facebook, Twitter, YouTube, Instagram), which constitute a rapid and interactive tool for transmitting and conveying information and exchanges between networks of people and organizations. The public disclosure of breaches must occur in compliance with the conditions set by the legislator in order for the person making it to benefit from the protections recognized by the decree.
Therefore, protection will be granted if one of the following conditions is met at the time of disclosure:
an internal report, to which the administration/entity has not responded regarding the measures planned or adopted to follow up on the report within the set terms
the person has already made an external report directly to ANAC which, however, did not provide feedback to the whistleblower regarding the measures planned or adopted to follow up on the report within a reasonable time (three months or, if justified and motivated reasons exist, six months from the date of the acknowledgment of receipt of the external report or, in the absence of such acknowledgment, from the expiry of seven days from receipt)
the person directly makes a public disclosure because, based on reasonable and well-founded grounds in light of the circumstances of the specific case, they believe that the breach may represent an imminent or manifest danger to the public interest. Consider, for example, an emergency situation or the risk of irreversible damage, including to the physical safety of one or more people, which requires the breach to be promptly disclosed and widely publicized to prevent its effects;
the person directly makes a public disclosure because, based on reasonable and well-founded grounds in light of the circumstances of the specific case, they believe that the external report may entail the risk of retaliation or may not be effectively followed up because, for example, they fear that evidence may be concealed or destroyed or that the recipient of the report may be in collusion with the author of the breach or involved in the breach itself. Consider, by way of example, the case where the person receiving the report of a breach, colluding with the person involved in the breach itself, proceeds to archive said report in the absence of grounds.
What happens if I make the report using other channels?
The "whistleblowing" regulation recognizes the whistleblower's right to protection regardless of the means of communication used, explicitly favoring the IT channel. The company has set up the IT reporting channel in order to guarantee the anonymity of the whistleblower. Any reports made to entities other than Lumina Fiduciaria or through other channels (e.g., email, PEC, regular mail, telephone) are by their nature not suitable for guaranteeing the whistleblower's anonymity. All parties involved will in any case handle the report with the utmost care and in accordance with the provisions of the regulations. Any reports made to entities not designated and therefore not trained to manage whistleblowing reports could compromise anonymity and make it impossible for the company to guarantee the whistleblower's rights.
How is the whistleblower's anonymity guaranteed?
The reporting process is managed on a complete outsourcing basis by Lumina Fiduciaria SPA, a trust company operating under authorization obtained from the Ministry of Economic Development (MISE) as established by Law 1966/39.
Lumina Fiduciaria collects reports through the dedicated portal www.WB24.it which, through encryption technology, separates the personal details of the whistleblower from the report itself.
The report will therefore be processed in a completely anonymous manner in accordance with the "whistleblowing" regulation, while the whistleblower's personal details will be stored and kept secret by the trust company and only accessible in the specific cases provided for by law.
What happens after the report is made?
Within seven days from the date of receipt, Lumina Fiduciaria issues an "acknowledgement of receipt". The anonymous "report" is immediately transmitted to the designated office of the reported company. In this specific case, the report is transmitted to the following subjects:
Chairman of the Board of Directors
Chief Executive Officer
Chairman of the Board of Statutory Auditors
Supervisory Body (ODV 231)
Whistleblowing management committee
* depending on the organizational model of the company subject to the report
Within the mandatory period of 3 months from the acknowledgement of receipt, the whistleblower must peremptorily receive the outcome of the report. The whistleblower will be able to consult the "acknowledgement of receipt", the outcome of the report, and any communications from the company by accessing the website anonymously at www.WB24.it
What can the whistleblower do if the reported company does not follow up on my report?
The "whistleblowing" regulation allows the whistleblower to make an external report directly to ANAC (National Anti-Corruption Authority) https://www.anticorruzione.it/-/whistleblowing in the event that:
After 3 months have passed since the report was made through the dedicated internal channel, the company has not provided any feedback.
The internal channel is not active or, if active, does not comply with the provisions of the decree.
the whistleblower has reasonable grounds to believe, based on concrete attached circumstances and information actually obtainable, and therefore not on mere rumor, that if they made an internal report:
it would not be effectively followed up. This occurs when, for example, the ultimate manager in the work context is involved in the breach, there is a risk that the breach or related evidence may be concealed or destroyed, the effectiveness of investigations by competent authorities might otherwise be compromised, or because it is believed that ANAC would be better suited to address the specific breach, particularly in matters within its competence;
this could lead to the risk of retaliation (for example, as a result of breaching the obligation to maintain the confidentiality of the whistleblower's identity).
the whistleblower has reasonable grounds to believe that the breach may constitute an imminent or manifest danger to the public interest. Consider, for example, cases where the breach requires urgent intervention to safeguard public health and safety or to protect the environment.
The "whistleblowing" regulation also allows the whistleblower to make a public disclosure.
Through public disclosure, information on breaches is made public through the press, electronic media, or otherwise through dissemination means capable of reaching a large number of people. The legislator naturally takes into account the evolution of mass media, including social networks and new communication channels (for example, Facebook, Twitter, YouTube, Instagram), which constitute a rapid and interactive tool for transmitting and conveying information and exchanges between networks of people and organizations. The public disclosure of breaches must occur in compliance with the conditions set by the legislator in order for the person making it to benefit from the protections recognized by the decree.
Therefore, protection will be granted if one of the following conditions is met at the time of disclosure:
an internal report, to which the administration/entity has not responded regarding the measures planned or adopted to follow up on the report within the set terms
the person has already made an external report directly to ANAC which, however, did not provide feedback to the whistleblower regarding the measures planned or adopted to follow up on the report within a reasonable time (three months or, if justified and motivated reasons exist, six months from the date of the acknowledgment of receipt of the external report or, in the absence of such acknowledgment, from the expiry of seven days from receipt)
the person directly makes a public disclosure because, based on reasonable and well-founded grounds in light of the circumstances of the specific case, they believe that the breach may represent an imminent or manifest danger to the public interest. Consider, for example, an emergency situation or the risk of irreversible damage, including to the physical safety of one or more people, which requires the breach to be promptly disclosed and widely publicized to prevent its effects;
the person directly makes a public disclosure because, based on reasonable and well-founded grounds in light of the circumstances of the specific case, they believe that the external report may entail the risk of retaliation or may not be effectively followed up because, for example, they fear that evidence may be concealed or destroyed or that the recipient of the report may be in collusion with the author of the breach or involved in the breach itself. Consider, by way of example, the case where the person receiving the report of a breach, colluding with the person involved in the breach itself, proceeds to archive said report in the absence of grounds.
What happens if I make the report using other channels?
The "whistleblowing" regulation recognizes the whistleblower's right to protection regardless of the means of communication used, explicitly favoring the IT channel. The company has set up the IT reporting channel in order to guarantee the anonymity of the whistleblower. Any reports made to entities other than Lumina Fiduciaria or through other channels (e.g., email, PEC, regular mail, telephone) are by their nature not suitable for guaranteeing the whistleblower's anonymity. All parties involved will in any case handle the report with the utmost care and in accordance with the provisions of the regulations. Any reports made to entities not designated and therefore not trained to manage whistleblowing reports could compromise anonymity and make it impossible for the company to guarantee the whistleblower's rights.
How is the whistleblower's anonymity guaranteed?
The reporting process is managed on a complete outsourcing basis by Lumina Fiduciaria SPA, a trust company operating under authorization obtained from the Ministry of Economic Development (MISE) as established by Law 1966/39.
Lumina Fiduciaria collects reports through the dedicated portal www.WB24.it which, through encryption technology, separates the personal details of the whistleblower from the report itself.
The report will therefore be processed in a completely anonymous manner in accordance with the "whistleblowing" regulation, while the whistleblower's personal details will be stored and kept secret by the trust company and only accessible in the specific cases provided for by law.
What happens after the report is made?
Within seven days from the date of receipt, Lumina Fiduciaria issues an "acknowledgement of receipt". The anonymous "report" is immediately transmitted to the designated office of the reported company. In this specific case, the report is transmitted to the following subjects:
Chairman of the Board of Directors
Chief Executive Officer
Chairman of the Board of Statutory Auditors
Supervisory Body (ODV 231)
Whistleblowing management committee
* depending on the organizational model of the company subject to the report
Within the mandatory period of 3 months from the acknowledgement of receipt, the whistleblower must peremptorily receive the outcome of the report. The whistleblower will be able to consult the "acknowledgement of receipt", the outcome of the report, and any communications from the company by accessing the website anonymously at www.WB24.it
What can the whistleblower do if the reported company does not follow up on my report?
The "whistleblowing" regulation allows the whistleblower to make an external report directly to ANAC (National Anti-Corruption Authority) https://www.anticorruzione.it/-/whistleblowing in the event that:
After 3 months have passed since the report was made through the dedicated internal channel, the company has not provided any feedback.
The internal channel is not active or, if active, does not comply with the provisions of the decree.
the whistleblower has reasonable grounds to believe, based on concrete attached circumstances and information actually obtainable, and therefore not on mere rumor, that if they made an internal report:
it would not be effectively followed up. This occurs when, for example, the ultimate manager in the work context is involved in the breach, there is a risk that the breach or related evidence may be concealed or destroyed, the effectiveness of investigations by competent authorities might otherwise be compromised, or because it is believed that ANAC would be better suited to address the specific breach, particularly in matters within its competence;
this could lead to the risk of retaliation (for example, as a result of breaching the obligation to maintain the confidentiality of the whistleblower's identity).
the whistleblower has reasonable grounds to believe that the breach may constitute an imminent or manifest danger to the public interest. Consider, for example, cases where the breach requires urgent intervention to safeguard public health and safety or to protect the environment.
The "whistleblowing" regulation also allows the whistleblower to make a public disclosure.
Through public disclosure, information on breaches is made public through the press, electronic media, or otherwise through dissemination means capable of reaching a large number of people. The legislator naturally takes into account the evolution of mass media, including social networks and new communication channels (for example, Facebook, Twitter, YouTube, Instagram), which constitute a rapid and interactive tool for transmitting and conveying information and exchanges between networks of people and organizations. The public disclosure of breaches must occur in compliance with the conditions set by the legislator in order for the person making it to benefit from the protections recognized by the decree.
Therefore, protection will be granted if one of the following conditions is met at the time of disclosure:
an internal report, to which the administration/entity has not responded regarding the measures planned or adopted to follow up on the report within the set terms
the person has already made an external report directly to ANAC which, however, did not provide feedback to the whistleblower regarding the measures planned or adopted to follow up on the report within a reasonable time (three months or, if justified and motivated reasons exist, six months from the date of the acknowledgment of receipt of the external report or, in the absence of such acknowledgment, from the expiry of seven days from receipt)
the person directly makes a public disclosure because, based on reasonable and well-founded grounds in light of the circumstances of the specific case, they believe that the breach may represent an imminent or manifest danger to the public interest. Consider, for example, an emergency situation or the risk of irreversible damage, including to the physical safety of one or more people, which requires the breach to be promptly disclosed and widely publicized to prevent its effects;
the person directly makes a public disclosure because, based on reasonable and well-founded grounds in light of the circumstances of the specific case, they believe that the external report may entail the risk of retaliation or may not be effectively followed up because, for example, they fear that evidence may be concealed or destroyed or that the recipient of the report may be in collusion with the author of the breach or involved in the breach itself. Consider, by way of example, the case where the person receiving the report of a breach, colluding with the person involved in the breach itself, proceeds to archive said report in the absence of grounds.
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Tailored technology
for all your needs.
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System Engineering
Database Administration
Tailored technology
for all your needs.
Services
System Engineering
Database Administration