This page summarizes in brief the most important steps of the Whistleblowing procedure, revised following the regulatory adaptation to Legislative Decree no. 24/2023. The procedure can be consulted in the attached files.
Who can make a report?
All those who want to raise an issue.
What can you report?
1. illegal activities, such as criminal acts such as non-compliance with non-disclosure obligations, fraud and corruption;
2. financial fraud, such as accounting manipulation, non-compliance with internal control procedures;
3. corruption or bribery;
4. Unlawful conduct pursuant to the D.lgs. 231/2001;
5. infringement of competition laws;
6. serious danger to the environment, health or safety, including food safety.
7. activities which, under laws, treaties or agreements, constitute a serious misconduct;
8. any other breach mentioned in the EU Whistleblowing Directive (Dir. UE n. 1937/2019)
What is not the subject of the report?
Everything related to your employment relationship or local workplace issues, such as conflicts with colleagues and executives, penalties, payment of wages and benefits. These cases should normally be reported to your immediate superior.
How can you file a report?
If you want to report a case that falls under the above procedure cases, you can do so:
Online via a dedicated portal accessible at this link
Via posta to the attention of the Destinatario Whistleblowing, addressed to Mr. Matteo Alessandro Pagani in Milano (MI) via Turati 26
If your request remains unaffected or there is imminent danger to public safety you can use the external reporting channel available in Italy (ANAC).
What does the reporting recipient do once the report is received?
The report is received via the dedicated portal
The report is analyzed by the whistleblowing recipient
The Recipient handles the report and finds the correct receipt within 7 days, considers the severity and credibility of the case and proceeds accordingly in determining the appropriate action.
The Recipient conducts the appropriate investigation and may also appoint external auditors, investigators and/or legal advisers to assist in the investigation and analysis of the results.
The conclusions of the investigation will be presented to the Board of Directors. You will receive feedback on your report within a reasonable period of time not exceeding 3 months from the date of your report.
What guarantees does SEVEN S.p.A. give you if you make a report?
All communications will beanonymous e confidential, unless you provide different instructions.
Unless the report is submitted anonymously, it will involve the processing of personal data (up to a maximum of 5 years from the final result). Examination of an alert may involve the collection and processing of additional information.
You can choose to close the communication channel at any time.
If you report a problem in good faith, we will ensure that there will be no discriminatory or retaliatory actions against you following a report. However, you will not be entitled to protection if you report bad faith.
All slanderous and defamatory reports are prohibited and sanctioned by law.