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Whistleblowing

Instructions for whistleblowing reports

Pometon SpA has always set itself, as a fundamental ethical principle, to carry out its business in full compliance with current legislation, as well as with ethical and behavioral principles based on correctness, integrity and legality of conduct.

The legislative decree 10 March 2023 n. 24, “Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 concerning the protection of persons reporting breaches of Union law and laying down provisions concerning the protection of persons reporting breaches of the provisions national regulations“, hereinafter also referred to as the “decree”. introduced the obligation to adopt a model for receiving and managing reports relating to violations of national and European regulations indicated therein, through internal reporting channels that guarantee the confidentiality of the reporting person (so-called whistleblower) and, within certain limits, also of the person reported, of the subjects involved and of the other subjects informed about the facts reported.

To this end, Pometon SpA has set up specific internal channels to receive reports of violations of the regulations in question, structured in such a way as to guarantee confidentiality and promote reports as a transparency tool to protect its corporate values.

PREMISE

Below are all the instructions and useful documentation for submitting a report.
 Please note that the following documents can be downloaded and consulted immediately:

     a. “WHISTLEBLOWING” PROCEDURE FOR RECEIVING AND MANAGING REPORTS PURSUANT TO THE LEGISLATIVE DECREE. 10.03.2023 N. 24”, which illustrates in detail how to report and the rules applied by Pometon SPA in managing reports;

     b. Privacy information pursuant to articles. 13 and 14 of Regulation (EU) 679/2016so-called GDPR regulation, which explains how the personal data of the reporter, the reported person and other subjects involved in the management of the report will be processed.

Below is a clear summary of the key points.

WHO CAN REPORT

They can submit a report:

  • employees, self-employed workers, holders of a collaborative relationship, volunteers and interns, including unpaid ones, who carry out their work at Pometon SPA;
  • workers or collaborators who carry out their work at entities that supply goods or services or that carry out works for third parties;
  • freelancers and consultants who work at Pometon SPA;
  • the shareholders and people of Pometon SPA with administration, management, control, supervision or representation functions.

The subjects indicated above can also report when:

a) the legal relationship referred to above has not yet begun, if the information on the violations was acquired during the selection process or in other pre-contractual phases;

b) during the probationary period;

c) after the dissolution of the legal relationship if the information on the violations was acquired during the relationship itself.

WHAT YOU CAN REPORT

Only the following violations may be filed:

  • illicit conduct foreseen by legislative decree 2001 n. 231 and violations of the relevant Pometon SPA model 231;
  • offenses that fall within the scope of application of the European Union acts indicated in Directive (EU) 2019/1937 and the national provisions that implement them;
  • acts or omissions that harm the financial interests of the European Union;
  • acts or omissions relating to the internal market (for example: violations relating to competition and state aid);
  • acts or behaviors that nullify the object or purpose of the provisions of the European Union acts referred to above.

The reports must concern information on the aforementioned violations of which the reporter has become aware within his/her work context.

Reports must be made in good faith and therefore concern facts for which the reporter has reasonable grounds to believe that the information reported is true at the time of submitting the report.

Reports should be made promptly with respect to knowledge of the facts so as to make their verification possible in practice.

The following do not constitute so-called whistleblowing reports: disputes, claims or requests linked to a personal interest of the whistleblower which relate exclusively to their individual employment relationship, or inherent to their relationship with hierarchically superior figures or the exercise of rights regarding personal data protection, commercial disputes or complaints.

INTERNAL REPORTING CHANNELS

The reporting party can report internally via these channels:

A) In written form, by filling out the form, divided into sections, present on the online platform at the internet address: https://pometon.whistleblowing.it, which presents suitable technical and organizational guarantees to guarantee the confidentiality of the reporter. The reporting party may indicate in the form how to be contacted:

  • directly via the platform, through an identification code issued immediately after completing the report which must be memorized by the reporting party or
  • by email or telephone or
  • by another suitable means.

    NB TO ALLOW THE ADMISSIBILITY OF THE REPORT TO BE VERIFIED, IT IS ESSENTIAL TO ATTACH AN IDENTITY DOCUMENT AND SUITABLE DOCUMENTATION TO CONFIRM THE ROLE CARRIED OUT BY THE REPORTER, WITH RESPECT TO THE COMPANY POMETON SPA.

    Click here to submit a report and then fill out the forms following the instructions therein;
     

B) In oral form, via telephone contact on the mobile number 331-6633-393, to which only the manager will respond, to be carried out in the morning from Monday to Friday from 10.00 to 12.30, excluding public holidays;

C) In oral form through a direct meeting with the internal reporting manager, at the request of the reporting party by telephone at the number indicated above, which will be fixed, within a maximum period of twenty working days, in the most appropriate location to guarantee its confidentiality.

The reports will be received and managed by the Internal Reports Manager, which is a dedicated internal office and whoever holds the position is required to maintain confidentiality in accordance with the provisions of decree 2023 n. 24 (on this point, see the privacy information and the whistleblowing procedure referred to in the links above).

It is also possible to submit anonymous reports, but if they are not duly detailed it will not be possible to proceed with their examination.

EXTERNAL REPORTING CHANNELS THROUGH THE ANAC (NATIONAL ANTI-CORRUPTION AUTHORITY) WEBSITE

The Legislative Decree 2023 no. 24 provides for the possibility of making external reports to the National Anti-Corruption Authority (ANAC) in the cases expressly provided for by the law.

In fact, the decree provides that in certain situations it is possible for the reporter to send the report using the reporting channels found on the ANAC website https://www.anticorruzione.it/, where you can find all the useful information.

The possibility of making external reports to the ANAC is permitted only in the following cases:

  • where the internal reporting channel is not active or if it does not comply with legal requirements;
  • in cases where the reporting party has already made an internal report which has not been followed up;
  • in cases where the reporting party has reasonable grounds to believe that, if he were to make an internal report, it would not be followed up effectively or that it could lead to the risk of retaliation;
  • in cases where the reporting party has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest.
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