Whistleblowing Reports | Nastri Brizzolari

In accordance with the provisions of Legislative Decree 24/2023, Francesco Brizzolari Srl has activated its whistleblowing reporting channels.

Who can report?

The reports that will be managed in accordance with Legislative Decree 24/23, can be made by the:

employees;
workers with part-time, intermittent, fixed-term, administration, apprenticeship, ancillary work contracts;
workers who perform occasional services;
self-employed workers who work for the Company;
freelancers and consultants who work for the Company;
volunteers and trainees, paid or unpaid, who work for the Company;
suppliers of the Company’s goods and services;
shareholders;
persons who, even de facto, hold functions of administration, management, control, supervision or representation of the Company.

All the subjects listed above can make Reports when the legal relationship with Francesco Brizzolari Srl:

is in place;
has not yet started, if the information was acquired during the selection process or at other pre-contractual stages;
after the closure of the same, if the information on the alleged violations was acquired during the course of the work activities, or during the probationary period.

What can be reported?

Information on violations of national or European Union regulatory provisions, which harm the public interest or the integrity of the Company, of which the whistleblower has become aware in the context of work, is reported.

The following are not whistleblowing reports:

Disputes, claims or personal requests relating to one’s employment relationship (to be sent to the competent company departments)
Complaints or disputes relating to the services provided by the Company (to be sent to the competent company departments)

How to report?

INTERNAL REPORTING CHANNELS

The reports can be made by means of the specific IT tool Whistleblowing made available by Galli Data service Srl (Manager of the reporting channel), by clicking here.
The tool allows you to make reports in written form, with the upload of videos and photos, as well as through the request for a meeting with the manager of the report.

Who is the reporting manager?
The person responsible for receiving and managing reports is the Committee of Segnalazioni.Il Committee of Reports, may avail itself of the support of specifically authorized internal resources by means of a specific communication given in writing. In addition, in carrying out the investigation, the Whistleblowing Committee may be supported by the competent company organisational structures from time to time or by the external professionals appointed for this purpose.

THE EXTERNAL REPORTING CHANNEL AND PUBLIC DISCLOSURE

The internal management channel is to be used as a priority.

Whistleblowers may use the external channel managed by ANAC, by connecting to the https://www.anticorruzione.it/-/whistleblowing website, exclusively in the following cases:

the Company has not activated an internal reporting channel or this does not comply with Legislative Decree 24/2023;
a report has already been made to the internal channel, but this has not been followed up;
the whistleblower has a well-founded fear of believing that, if he uses the internal channel, he would not receive effective follow-up or could be subject to retaliation;
the whistleblower has reasonable grounds to believe that the breach may constitute an imminent or obvious danger to the public interest.

Whistleblowers may also make public disclosure (press and other means of dissemination such as social networks), if one of the following conditions is met:

the whistleblower has previously made an internal and external report or has directly made an external report and has not been given feedback within the established deadlines regarding the measures envisaged or adopted to follow up on the reports;
the whistleblower has reasonable grounds to believe that the the breach may constitute an imminent or obvious danger to the public interest;
the whistleblower has reasonable grounds to believe that the external report may involve the risk of retaliation or may not be effectively followed up due to the specific circumstances of the case, such as those in which evidence may be concealed or destroyed or where there is a well-founded fear that the person receiving the report may be colluding with or involved in the breach in the violation itself.

This is without prejudice to the possibility of reporting to the competent national judicial and accounting authorities.

In implementation of the above, Francesco Brizzolari Srl has adopted the “Whistleblowing Procedure”, which can be consulted here.

For a complete analysis:

of the subjects who can make the reports,
of the subject of the reports,
of the reporting channels,
of the methods of managing the same,
of the protections guaranteed to whistleblowers, to those reported in bad faith and to the other subjects indicated in the law, as well as for anything not indicated in this policy, please refer to the Procedure.