WHISTLEBLOWING - REPORTING CHANNEL

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The term whistleblowing refers to the voluntary disclosure made by an employee who, in the performance of his or her duties, becomes aware of illegal, unethical, or fraudulent behaviors carried out within an organization.
GIVA Group provides the opportunity to report such offenses through a dedicated platform that guarantees confidentiality of the reporter's identity.

The objective of adopting this tool is to prevent non-compliance occurrences or wrongdoings within the Group engaging employees, through an active and responsible participation, in the fight against illegal behaviors. Responsible reporting, made in good faith and in the interest of the common good, enable the Group to intercept in time, provide a remedy and prevent illegitimate behaviors and illegal actions of corruption, fraud or other violations of the Group’s Code of Conduct.

WHO CAN REPORT

Reporting can be made by:

  • all Group employees, regardless their contract conditions and job position.
  • shareholders (natural persons) and any person holding supervisory, representative, or managerial functions within the Group.
  • self-employed workers and collaborators, who provide goods, services, or carry out activities in favor of the Group.
  • interns and trainees, who execute their activities within the Group's work environment.
  • freelancers and consultants who perform their activities for the Group.
Reports may also be submitted by a person involved in the recruitment process or pre-contractual phase, as well as in the trial period or after termination of the employment (only if the information was acquired during the employment period).

WHAT CAN BE REPORTED

Reports shall relate to:

  • unlawful conducts envisaged by the Legislative Decree 231/2001.
  • any offence falling within the scope of the European Union or national regulations relating to the sectors identified by Legislative Decree 24/2023.
  • Code of Conduct violations as well as breaches of company procedures.

WHAT CANNOT BE REPORTED

The following reports are excluded and therefore inadmissible:

  • reports related to the whistleblower personal interest, or exclusively pertaining his or her individual working relationships with colleagues or hierarchical superiors.
  • reports based on mere suspicions or rumors.
  • reports related to national security violations.
The reporting channel should not be used also to submit complaints or information requests regarding ongoing contracts with GIVA Group companies.

HHOW TO MAKE A REPORT

GIVA Group has set up a dedicated reporting channel available to whistleblowers. The platform uses a web-based solution that offers a customized portal for each Group company, thereby ensuring compliance with all the necessary legal requirements, including those of personal data processing and privacy regulation.

Reports should provide the following elements:

  • a full description of the facts being reported.
  • circumstances of time and place in which violations were committed or for which allegations are made.
  • if known, personal details or other elements (job position, organizational-unit, activity carried out) to enable the identification of the reported person.
  • details of any witness or person who could provide additional information on the facts reported.
  • any annexes or documents to support the validity of the facts reported.
  • any further information that may provide valuable evidence of the facts reported.
By clicking on the 'File a Report' button, the whistleblower will choose the Group’s company for which the report is being sent. The whistleblower may submit a report either declaring his/her identity or remaining anonymous. To facilitate the investigation and be contacted if needed, it is recommended that the whistleblower specifies his/hers reference details. It is also possible to request a face-to-face meeting with the whistleblowing investigation team.

The content provided in case of anonymous reports is crucial for their 'taking charge' and follow-up; therefore, due consideration will be given only to reports that are substantiated and accompanied by adequate evidence.

For further operational details concerning the use of the Whistleblowing platform, please refer to the "User Manual" d downloadable at the link below.

WHO RECEIVES THE REPORT

Click the button at the bottom of the page to access the reporting platform. Reports are received by a team of experienced professionals external to the organization (outsourcer). The outsourcer is committed to confidentially and bounded, in accordance with current legislation, not to disclose the whistleblower’s identity without his/her consent. Any personal data is processed in compliance with the current privacy regulation.

The whistleblowing team that manages the report will automatically issue an acknowledgement of receipt to the whistleblower within seven days from the report submission.

In order to give proper follow-up to reports, the whistleblowing team carries out a first assessment to verify that the basic requirements of the report are met to proceed in the process (preliminary investigation). After the report is evaluated to be eligible for processing, the whistleblowing team takes by all possible means the necessary investigative actions to further follow up the report, including interviews and documents acquisition, always in accordance with the principles of impartiality and confidentiality.

Upon completion of the investigation and, in any case, within 3 months from the date of the acknowledgement of receipt, the whistleblowing team is committed to provide feedback to the whistleblower, unless for well-grounded reasons, the deadline is extended to 6 months.

PROTECTION AND RESPONSIBILITY OF PEOPLE INVOLVED

Information must be reported in good faith, providing full details. The information provided will be treated according to the confidentiality criteria. The whistleblower who reports in good faith is protected against any possible retaliation measure.

During the investigation activities, the reported person(s) may be involved or notified of the ongoing procedure; nonetheless, under no circumstances, any proceedings will be initiated if not in presence of rehearsed and concrete evidence of the contents reported.

It is the whistleblower’s responsibility to make reports in good faith and in accordance with the stated intent of this procedure. Reports that are manifestly unfounded, opportunistic and/or submitted for the sole purpose of harming the reported person(s), will not be considered and will be liable to disciplinary sanctions and/or legal proceedings.