Introduction to Whistleblowing
Fima Carlo Frattini SpA fosters an open corporate culture, marked by ethics, transparency and responsibility, and inspired by the Company’s values: for this reason it asks its people, such as directors, managers, supervisory bodies, managers, employees and other collaborators, and all its partners, to operate in full compliance with the Laws and Regulations, Code of Ethics and Human Rights.
The Company strongly encourages its stakeholders to report (so called whistleblowing) any improper, dishonest or illegal activity – potential, highly probable or already committed – as well as any behaviour that may cause damage or harm, including image damage, to Fima Carlo Frattini SpA. To this end, the company has implemented specific rules and a management process in compliance with the ‘Whistleblowing’ regulation Legislative Decree 24/2023 in order to provide potential whistleblowers with safe channels that guarantee the confidentiality of their identity and of the information contained in the report and their protection from possible retaliation. Reports concerning personal interests of the whistleblower, complaints or grievances of a personal or commercial nature, claims or demands falling within the scope of the employment relationship are excluded from the scope of the legislation. In the event of reports that are unfounded, made in bad faith or with gross negligence, the Company reserves the right to act in defence of its interests and to protect the injured parties.
Management of alerts
Fima Carlo Frattini SpA has appointed for the management of whistleblowing reports a Committee of external experts in whistleblowing legislation, organisational models pursuant to legislative decree 231/01 and management systems, Union law and industrial relations and labour law, with autonomy, impartiality and independence with respect to the processes that could be the subject of reports. It has also made available an external digital platform, managed by a specialised third party, in order to ensure the effectiveness and confidentiality of the whistleblowing process and provide extended and indiscriminate access to all those who wish to make a report. The Company encourages whistleblowers to give preference to identified and non-anonymous reports, in order to streamline and make investigations more effective, although anonymous reports are equally accepted, provided they are fully substantiated.
In order to ensure the effectiveness of the whistleblowing process and to provide extended and indiscriminate access to all those who wish to make a report, it has made available a number of alternative communication channels, such as:
- IT platform accessible at the following link: https://whistleblowing.fimacf.com/#/
- Oral reporting to the Committee of Experts at SIN srlu (after requesting an appointment via the platform or alternatively at the dedicated e-mail address wh************@cn**.it) by recording it on a device suitable for storage and listening or by means of minutes; in the case of minutes, the reporting person can check, correct and confirm the minutes of the meeting via their dedicated e-mail address. A file with a voice message, supporting the report, can be uploaded through the platform. Use the « voice recorder » functionality available on every mobile device.
- Registered mail with return receipt to be addressed to: SIN srlu, with registered office in Novara, Corso Cavallotti no. 25 The report must be placed in two sealed envelopes: the first with the reporting party’s identification data together with a photocopy of the identification document; the second with the report, so as to separate the reporting party’s identification data from the report. Both should then be placed in a third sealed envelope marked ‘confidential’ on the outside. The report will be subject to confidential registration by the reporting manager.
Monitoring of the functionality of the above-mentioned communication channels is ensured by the Whistleblowing Committee, which should be contacted in the event of any malfunctioning.
