GE.S.A.C guarantees special attention to the prevention of risks that could compromise the proper and responsible management of its business consistent with its mission and internal control system, as well as the need to know about potential critical situations in order to correct them in a timely manner by consolidating the relationship of trust with stakeholders.
For this reason, in order to ensure fairness and transparency in the conduct of business and activities carried out, GE.S.A.C has provided specific internal channels to receive Whistleblowing reports regarding potential violations of national and European regulations such as may cause damage or harm to the Company (e.g., a fraud, a generic risk or a potentially dangerous situation), while also ensuring compliance with the regulatory provisions set forth in Legislative Decree No. 24 of March 10, 2023 on Whistleblowing.
Who can make a Whistleblowing report
Individuals who work in the Company's working environment may make a report, as:
• employees;
• self-employed workers;
• collaborators, freelancers and consultants;
• volunteers and interns, paid and unpaid;
• -shareholders and persons with functions of administration, management, control, supervision or representation, even if these functions are exercised on a de facto basis.
The Whistleblower is entitled to make its report:
• when the legal relationship is ongoing;
• during the trial period;
• when the legal relationship has not yet begun if the information on violations was acquired during the selection process or other pre-contractual stages;
• after the dissolution of the legal relationship if the information on violations was acquired before the dissolution of the legal relationship.
How to make a Whistleblowing report
GE.S.A.C. has set up an online IT system, which can be accessed at https://whistleblowinggesac.segnalazioni.net, in order to enable the submission of Whistleblowing reports in written form (by following the completion of the prescribed fields) or in oral form (by voice recording or by requesting a direct meeting with the individuals specifically authorized to collect the reports), either in a named (registered user) or anonymous (unregistered user) manner.
What can be the content of a Whistleblowing report
The content of a Whistleblowing report may be conduct, acts or omissions that harm the public interest or the integrity of the Company consisting of:
• violations of national regulatory provisions, such as administrative, accounting, civil or criminal offenses, illegal conduct relevant under Legislative Decree 231/2001 or violations of the Company's Model 231 and its annexes;
• violation of European regulatory provisions, such as offenses falling within the scope of European Union acts relating to specific sectors such as, but not limited to, public procurement, services, products and financial markets, etc.
Reports must be duly substantiated in order to enable the assessment of facts and based on precise and concordant facts.
In particular, it is necessary to be clear:
• the circumstances of time and place in which the fact that is the content of the report occurred;
• the description of the fact;
• the generalities or other elements that make it possible to identify the person to whom the reported facts are attributed.
Receipt and management of Whistleblowing report
The responsible subjects for receiving and handling Whistleblowing reports are:
• the WHISTLEBLOWING COMMITTEE
• the ETHICS COMMITTEE (for reports involving one or more members of the Whistleblowing Committee or the Company's Supervisory Board or a conflict of interest).
Furthermore, in the event that a report is received concerning a potential violation of the Company's Organization, Management and Control Model pursuant to Legislative Decree 231/01 ("Model 231"), the Whistleblowing Committee/Ethics Committee will share it, through the aforementioned IT System, with the Supervisory Board for the purpose of carrying out the relevant checks.
All personal data will be processed in accordance with the current Privacy Regulations, in full respect of fundamental rights and freedoms, with regard to the confidentiality of the identity of the individuals involved and the security of the processing also in accordance with the provisions of the Whistleblowing Decree.
Please refer to the Whistleblowing Policy adopted by GE.S.A.C. for further details regarding the content of reports.
