In accordance with the best international standards, the reports that you place through the dedicated page (external service) will be handled to ensure maximum protection of those who send communications or requests for information and in accordance with the applicable legal provisions on the personal data protection. The information you provide will be handled to ensure maximum protection to you and, if requested, handled completely anonymously and exclusively by EthicPoint’s independent service.

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Whistleblowing: I want to learn more about it

 A proper and effective whistleblowing mechanism is crucial to ensure compliance with legal and transparency principles and corporate policies

A proper and effective whistleblowing mechanism is of utmost importance to uphold legal and transparency principles defined by the company in compliance with applicable laws and company policies. It helps identify and address any wrongdoing, protects shareholders from economic losses and damage to their reputation, spreads a culture of ethics, legality, and transparency within the company, and reinforces internal control and risk management systems.

The objectives of the company through this procedure are:

• To ensure transparency and effectiveness of reporting channels;
• To timely manage the reported issues in line with applicable procedures;
• To ensure the protection of the personal data of reporters and, upon request, anonymity.
• To safeguard the reporters from possible retaliation.

The aims are, so, to encourage and facilitate reporting within the organization and mitigate risks of wrongdoing, building and strengthening trust with stakeholders, and promoting a corporate culture of transparency, integrity, good governance, and corporate compliance.

The System EthicPoint

EthicPoint is an external and certified service for privacy protection. Its approach is that of a service, providing more than just a reporting channel; instead, it offers a true assistance and consulting service to the reporter, which the reporter can use even without reporting.

This is essential to ensure that experts of EthicPoint are contacted before any action is taken to ensure all necessary information is provided.

1       Purpose and scope[1]

This document defines the rules for proper and effective management of a report by a subject (Reporter), also with the aim of identifying and removing potential risk factors and activating, if necessary, the competent authorities.

The objective of this document is to provide the reporter and all parties involved with clear operational guidelines on the subject, content, recipients, transmission methods, and management of reports, as well as all forms of protection provided under the law and internal procedures.

This procedure has also been defined as a guide for the preparation of circulars or informative and educational documents for the parties involved.

It applies to all activities carried out by the Company.

2       Terms and definitions: essential concepts to know

Before proceeding with the reading of this procedure related to the management of reports, it is recommended to read the entire regulation (Legislative Decree 24/2023) in which terms and definitions in the field of Whistleblowing are indicated. 

2.1      What can be reported and what cannot be reported

Taking into account what is also provided for by other regulations and best practices of reference, the report may concern actions or omissions, committed or attempted, that:

• violate national or European Union regulatory provisions that harm the public interest or the integrity of public administration or private entities, of which they have become aware in a public or private work context, specifically mentioned in Decree 24 of March 10, 2023;
• are subject to administrative or criminal sanctions or other administrative measures, including against the Company in accordance with Legislative Decree 231/2001, where applicable;
• are attributable to the abuse of power entrusted to an employee, in order to obtain private benefits;
• evidence a malfunctioning of the Company due to the private use of the assigned functions (for example: waste, nepotism, repeated failure to comply with procedural deadlines, non-transparent hirings, accounting irregularities, false statements, violation of environmental and occupational health and safety regulations);
• are carried out in violation of the Code of Ethics, the internal company regulations, the Organizational, Management and Control Model pursuant to Legislative Decree 231/2001, where applicable, or other company provisions subject to disciplinary action;
• could cause financial or reputational damage to the Company or its shareholders;
• could cause harm to employees or other individuals carrying out their activities within the Company.

Only violations concerning Dallan s.p.a. which the reporting person has certain knowledge of or reasonable suspicion based on certain and concrete facts can be reported.

Violations that cannot be reported include:

• disputes, claims or requests related to a personal interest of the reporting person;
• disputes, claims or requests that exclusively relate to the employment relationship of the reporting person and relationships between them and their hierarchical superiors;
• complaints, disputes or requests of a general nature or that do not specifically relate to one of the previously listed violations;
• reports related to information covered by legal or medical secrecy or falling under the principle of confidentiality of judicial proceedings.

Important: if a worker believes to have suffered violations of their own personal interest or in the context of their employment relationship or the management of relationships with their hierarchical superior, they will always and nevertheless be required to use ordinary remedies and protections, such as, for example, discussing the matter with their employer, seeking assistance from unions, or resorting to legal assistance.

3      Signalling channels

3.1      Signalling tools

The Company has established an independent and certified reporting channel by providing a specific address for the collection and management of reports.

The adopted channel allows reporting of any violation provided for by Decree 24 of 2023 and company procedures by all stakeholders, both internal and external, ensuring effective and confidential communication.

The activated reporting methods are as follows:

In accordance with Article 4, paragraph 3 of Legislative Decree 24 of 2023, the Reporter can request a face-to-face meeting to orally present their report.

4      Reporting management

4.1    T he subjects involved (potential reporters)

The Company identifies internal and external stakeholders as potential reporters. For example, these include:

• Employees of public administrations, employees of public economic entities, employees of privately controlled legal entities, in-house companies, public legal entities, or public service concessionaires;
• Subordinate workers of private sector entities;
• Self-employed workers, freelancers, and consultants who carry out their activities for public or private sector entities;
• Volunteers and interns, both paid and unpaid, who carry out their activities for public or private sector entities;
• Shareholders and individuals with administrative, managerial, supervisory, or representative roles;
• Facilitators;
• Persons in the same work environment as the reporting person, who have a stable emotional or familial relationship up to the fourth degree of kinship;
• Co-workers of the reporting person who work in the same work environment and have a regular and ongoing relationship with the reporting person.

This also applies when:

• The legal relationship has not yet started, if information on violations has been acquired during the selection process or other pre-contractual stages;
• During the probationary period;
• After the termination of the legal relationship, if information on violations has been acquired during the relationship itself.

4.2    Confidentiality obligation

The aim of this procedure is to ensure the protection of the Reporter, keeping their identity confidential only in the case of reports from identifiable and recognizable individuals.

Anonymous reports, if adequately detailed and provided with sufficient information, i.e., capable of highlighting facts and situations relating to specific contexts, are treated in the same way as ordinary reports. Anonymous reports and their processing are carried out using the same tools provided for confidential reports, even if communication with the anonymous reporter is not possible after the report itself.

4.3    Recipients of the report

Internal references are:

5       Procedure and tasks of those receiving the report

5.1      Verification of the validity of the report

EthicPoint takes charge of the report, which is then transmitted to the appropriate internal functions, and provides the reporter with a receipt notification within 7 days from the date of receipt.

The internal functions diligently follow up on the received reports and provide a response within 3 months from the date of the receipt notification, or if no notification was given, within three months from the expiration of the 7-day deadline from the submission of the report, using the above-mentioned email address or through the contact information provided by the reporter.

All information will be handled in accordance with the provisions regarding the protection of the reporter.

If necessary, the internal functions may request clarifications from the reporter or any other parties involved in the report, taking the necessary precautions.

They also verify the validity of the circumstances represented in the report through any appropriate activities, including obtaining documentation and hearing any other individuals who can provide information on the reported facts, while respecting the principles of impartiality, confidentiality, and protection of the Reporter’s identity.

Based on an assessment of the facts reported, the Company may decide to archive the report in cases of evident and manifest invalidity.

The Company may directly archive reports in certain cases.

If there are elements indicating non-evident invalidity of the facts, the designated internal functions forward the report, including for the adoption of subsequent measures, to the competent individuals designated by the Company.

5.2      Verification of the validity of anonymous reports

The verification phase of the validity of the report by the Company is the same for both confidential and anonymous reports. However, for anonymous reports, the following considerations apply:

• The need for further investigation into the elements that exclude direct archiving;
• Contact with the Reporter by the Company will take place if technically feasible.

6      Whistleblower protection

The Company formally declares that no form of discrimination or retaliation will be taken against the whistleblower; in fact, any behavior in that direction will be penalized. In accordance with Article 17 of Decree Law 24 of 2023, whistleblowers are explicitly protected from any form of retaliation. This protection is not applicable in cases where false information is reported with deliberate intent or gross negligence. In case of suspected discrimination or retaliation against the whistleblower related to the report or abuse of the whistleblowing procedure by the same person, the Company may impose disciplinary sanctions. The Company provides the following types of support to the whistleblower:

• Information;
• free consultation and assistance on the reporting procedure and protection from retaliation.

7      Liability of the whistleblower

This policy releases the organization from criminal, civil, and disciplinary liability in the event of a false or defamatory reporting in accordance with penal codes and Article 2043 of the Civil Code.

Additionally, any forms of abuse of this policy, such as opportunistic reporting or reporting solely to harm the accused or other parties, as well as any other improper or intentional misuse or instrumentalization of the organization, shall be subject to disciplinary action and legal liability in appropriate venues. This also includes frivolous reporting committed with intent or gross negligence.

8      The disciplinary system

A effective whistleblowing system should provide for sanctions against both the whistleblower in cases of abuse of the reporting mechanism, and against the individuals under investigation when their wrongdoing is confirmed in accordance with the applicable legislation, including collective bargaining agreements, such as the Decree Law 24 of 2023 concerning the protection of persons reporting violations of European Union law and national legislation.

9      Additional information and contacts

For any additional information regarding the Whistleblowing procedure, you can contact:

[1] Regulatory references: Legislative Decree 24 of 10 March 2023, ANAC Guidelines.