The REPORTING PORTAL
The Clementoni Group has set up the Whistleblowing Portal for those who intend to make report of the following conduct, acts or omissions:
- administrative, accounting, civil or criminal offences;
- unlawful conduct pursuant to Italian Legislative Decree 231/2001 or violations of organisational models;
- offences falling within the scope of EU or Italian acts (public procurement; financial services, products and markets, and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; protection of privacy and protection of personal data and security of networks and information systems);
- acts or omissions that harm the financial interests of the EU, protected pursuant to art. 325 of the TFEU;
- acts or omissions concerning the internal market, pursuant to art. 26(2) of the TFEU, including violations of EU competition and state aid rules as well as corporation tax;
- acts or conduct that undermine the object or purpose of the provisions referred to in EU acts in the areas indicated in points c), d) and e);
- information relating to conduct aimed at concealing the violations indicated above;
- illegal activities not yet carried out but that the Whistleblower reasonably believes may occur in view of specific and consistent elements;
- grounds for suspicion.
Reports must be made to protect the integrity of the Company and must be based on precise and consistent facts.
METHOD OF TRANSMISSION OF THE ALERT
Access to the Portal is managed in no-log mode, in order to prevent the identification of the whistleblower who intends to remain anonymous.
After access, the whistleblower will be guided in filling out a questionnaire consisting of open and / or closed questions that will allow to provide the elements characterizing the report (facts, temporal context, etc.).
At the end of completing the questionnaire, the Portal will ask the whistleblower whether or not he intends to provide his identity. In any case, the whistleblower may provide his/her personal details at a later time, always through the Portal.
At the time of sending the report, the Portal will issue the whistleblower with a unique identification code (ticket). This number, known only by the whistleblower, cannot be recovered in any way in case of loss. The ticket will be used by the whistleblower to access, through the Portal, his report in order to: monitor its progress; insert additional elements to substantiate the report; provide your personal details; answer any follow-up questions. The Portal allows, in fact, to establish a virtual interview (chat) between the whistleblower and the recipient, if you want, always in a completely anonymous form.
WHO HANDLES THE REPORT
The task of managing reports is entrusted to the Supervisory Body of Clementoni S.p.A.
PROTECTION AND MANAGER OF THE WHISTLEBLOWER
No retaliation or discrimination, direct or indirect, can arise on the part of those who have made a report in good faith. In addition, sanctions are provided for those who violate the measures to protect the whistleblower.
Sanctions are provided for the whistleblower, where possible, in the case of reports made with willful misconduct or gross negligence or that prove to be false, unfounded, with defamatory content or in any case carried out for the sole purpose of damaging the Company, the reported or subjects affected by the report. The Company may also take appropriate initiatives in legal proceedings.
PROTECTION OF THE REPORTED
The report is not sufficient to initiate any disciplinary proceedings against the reported. If, following concrete feedback acquired regarding the report, it is decided to proceed with the preliminary activity, you can contact the reported person who will be guaranteed the right to provide any necessary clarification.
Any personal and sensitive data contained in the report, including those relating to the identity of the whistleblower or other individuals, will be processed in full compliance with EU and national legislation on the protection of personal data.
PROCEDURE TO FOLLOW
For more information of how the Clementoni Group handles any reports, please refer to the "Policy Whistleblowing" Procedure downloadable on the Platform.