WHISTLEBLOWING

PROCEDURE FOR ETHICAL BREACHES

THE CRIVELLI SRL WHISTLEBLOWING PROCEDURE  

CRIVELLI SRL is committed to full observance of the laws and regulations and ensuring that the company’s Code of Conduct rules are respected.

The Whistleblowing Procedure makes it possible to report information regarding crimes, offences, threats or damages against the public interest, breaches or attempts to cover up violations of applicable and binding legislation (laws, regulations, etc.) and, more generally, violations of national or European Union legislative provisions which harm the public interest or the integrity of the Company; finally, it allows violations of the Code of Conduct to be reported.

Whistleblowing reports are handled confidentially and by the applicable regulations.

Whistleblowers enjoy protection against the risk of retaliation as provided by the regulations.

Improper use of the Whistleblowing Procedure may expose the Whistleblower to disciplinary sanctions (in the case of an employee) or to other types of sanctions, where provided for by the applicable regulations. However, using this Procedure in good faith shall not lead to any disciplinary sanctions, even if the facts are later found to be inaccurate or do not lead to any action being taken.

The personal data and information acquired by the company regarding which the Whistleblowing report is sent shall be processed by that company in the role of Data Controller for the management thereof. They shall be stored for no longer than five years from the date on which the outcome of the whistleblowing procedure is communicated, and the purpose for their processing is compliance with a legal obligation concerning the scope of application of Italian Legislative Decree No. 24 of 10 March 2023.

When should I make a report?
When you have reason to believe that there has been a breach of law or of the Code of Conduct, or in the event of a threat or damage to the public interest.

How can I make a report?
Go to the following address https://whistleblowing-crivelli.hawk-aml.com/Whistleblowing/home

Can reports be made anonymously?
Yes, reports can be made anonymously.
However, it is recommended that you provide information to allow the Whistleblowing Contact Person to contact you.

Will I be informed of the follow-up to my report?
Confirmation of receipt will be sent within seven days of receiving the report, and you may be asked several questions so that the investigation can be conducted appropriately. Information will also be provided about the report management status and the outcome of the investigation.

The time frames for managing reports are as follows:

  • 7 days for the report to be taken on board
  • 15 days for the evaluation of the problem
  • 90 days for full processing
  • 1,826 days before the data are deleted
  • 3 days for the notification email before deletion of the data

Is confidentiality guaranteed?
Yes, the Whistleblowing Contact People are trained to handle Whistleblowing reports confidentially and adopt all the appropriate measures for that purpose.