In compliance with Legislative Decree 24/2023 (the so-called “Whistleblowing Decree”) and in full compliance with applicable regulations, Italmobiliare has adopted a whistleblowing procedure to help prevent offences and violations committed while working at Italmobiliare.
Italmobiliare guarantees protection of the identity of the whistleblower and of the people involved in and/or mentioned in the report, as well as confidentiality regarding its content. The Company also undertakes to implement every form of protection envisaged by the law against retaliatory or discriminatory conduct.
The identity of the whistleblower and any other information from which such identity could be deduced cannot be communicated, without the person's express consent, to parties other than those responsible for receiving or following up on reports.
Who can act as whistleblowers?
According to the provisions of art. 3 of the Decree, those who can act as whistleblowers are:
- employees, also during their trial period, self-employed workers, as well as collaborators, freelancers and consultants who work at the Company;
- shareholders and those with administrative, management, control, supervisory or representative functions;
- trainees working for the Company;
- workers or collaborators of the Company's contractors, subcontractors and suppliers;
- former employees of the Company;
- candidates for a job at the Company, who have acquired information on the violations during the selection process or in other phases of the pre-contractual negotiation.
In other words, anyone who comes into contact with the Company in whatever capacity.
What can be reported by a whistleblower?
Matters that can be reported include behaviour, acts or omissions committed or which, based on concrete elements, could be committed within the working environment of Italmobiliare in violation of national or European Union regulatory provisions referred to in art. 2 of the Decree, as well as violations of the Code of Ethics, of the Organisation and Management Model pursuant to Legislative Decree 231/2001, employment contracts and internal regulations (rules, policies, procedures, operating instructions, etc.).
The report must be complete, exhaustive and detailed, so the whistleblower is required to provide all available elements that may be of use to allow appropriate checks and investigations needed to verify the matters being reported.
Internal reporting channels
For whistleblowers to make reports, Italmobiliare has made available the following channels:
- online platform, accessible from the following link https://italmobiliare.integrityline.com;
- ordinary mail, to be sent to: Italmobiliare S.p.A. – Via Borgonuovo 20, 20121 Milan (MI) – for the attention of the Supervisory Body;
- meeting directly with the Supervisory Body.
Note that the online platform makes it possible for reports to be transmitted both in writing and orally, in ways that also maintain anonymity.
The Supervisory Body receives and manages any reports that arrive, updating the whistleblower on the progress being made on the case with the following timing:
- an acknowledgement of receipt is to be issued within 7 (seven) days of receiving the report;
- within 3 (three) months from the date of acknowledgement of receipt or, in the absence of such notice, within 3 (three) months from expiry of the seven-day period from submission of the report, feedback is provided on the follow-up already given on the matter and which the Company intends to give in the future.
How are personal data processed?
As part of the whistleblowing procedure, personal data are processed in compliance with current legislation (EU Regulation 679/2016 and Legislative Decree 196/2003, as amended by Legislative Decree 101/2018).
For further details on the processing of personal data, you can consult the Information herein.
The above information, provided in compliance with current legislation, constitutes an extract of the Whistleblowing Procedure adopted by the Company.