This procedure aims to describe the activities, roles, related control responsibilities, and management of violation reports, introducing organizational measures aimed at application:

  • of the soft law by Anac
  • of legislative decree no. 24/2023 and specifically
    1. of the European provisions listed by legislative decree no. 24/2023 that seek public interest or the Company's integrity
    2. of measures for the protection and safeguarding of individuals making reports and subjects indicated by the same legislative decree no. 24/2023

The procedure aims to regulate the process of receiving, analyzing, and managing reports, sent or transmitted by anyone. Although there is currently no exhaustive list of crimes or irregularities that may constitute the subject of reports, those concerning behaviors, risks, crimes, or irregularities, committed or attempted, to the detriment or advantage of the Company, even solely in terms of image, are considered relevant. These include those defined as 'predicate offenses', or mere violations of the Model and the Code of Ethics, as well as non-compliances related to the failure to comply with hygiene, production, analytical, and corporate control standards and procedures. In particular, reports may concern the following areas:

  • communications of alleged or actual violations, requests, or inducements to violate laws or regulations, Code of Ethics prescriptions, internal operating procedures and instructions, concerning activities and performances of interest to the Company;
  • communications of alleged or actual violations also following behaviors at risk of crime and/or illicit activities provided by company management procedures.

Whistleblowing cannot concern personal complaints of the reporter or claims/requests falling within the discipline of the employment relationship or relationships with superiors or colleagues, for which reference should be made to the applicable regulations concerning subordinate employment relationships.


The responsible party

The manager of the reporting process is exclusively the ODV.

Submission of reports

As soon as a recipient becomes aware, directly or indirectly, of a 'critical' event relating to offenses/regulatory non-compliance, illicit conduct that may concern the Company, they must report it and, if possible, attach any supporting documentation considered useful, refraining from taking any autonomous analysis and/or investigation initiative. Failure to communicate a received report constitutes a violation of this procedure, with the application of consequent disciplinary sanctions. All reports can be:

  • sent to the ODV at the email address [email protected]
  • Through the online platform available on this company website, suitable for ensuring the confidentiality of the reporter's identity through computerized methods. Each report is received by the ODV (Vigilance Body), which issues a receipt notice to the reporter within seven days from the date of receipt, and will respond to the report within three months from the date of the receipt notice.

The report is managed in compliance with the principles of confidentiality, and the reporter's identity, if any, is not disclosed without their consent. Any personal data present is treated in compliance with the current Privacy regulations and stored for the strictly necessary period for managing the report.


All reports are subject to preliminary analysis carried out by the ODV to verify the presence of useful data and information to enable an initial assessment of the validity of the report. In conducting the aforementioned analysis, the ODV may use external or internal resources of the Company. If, at the conclusion of the preliminary analysis phase, there is a lack of sufficiently substantiated elements or, in any case, the invalidity of the facts referred to in the report, the ODV archives it, with the relative reasons. If, instead, at the conclusion of the preliminary analysis phase, it emerges that the report does not fall within the types of competence as defined above, the ODV will arrange for its forwarding to the competent offices.


With the exception of cases where liability for defamation and slander is applicable, pursuant to the provisions of the criminal code or art. 2043 of the civil code, and cases where anonymity is not legally opposable (e.g., criminal, tax, or administrative investigations, inspections by control bodies), the identity of the reporter is protected in all contexts following the report. To protect the reporter reporting illegalities and ensure the effectiveness of the process, the Company, also through the reporting system, will:

  • manage reports transparently through the procedural process provided by the procedure;
  • protect the confidentiality of the reporter's identity;
  • protect the Management from pressures and discriminations;
  • protect the confidentiality of the report's content.

The procedure does not prejudice the criminal and disciplinary responsibility of the reporter in the event of a slanderous or defamatory report under the criminal code and art. 2043 of the civil code. Forms of abuse of the procedure, such as blatantly opportunistic reports and/or made solely to harm the reported party or other subjects, and any other misuse or intentional instrumentalization of the procedure institution are also sources of responsibility in disciplinary and other competent forums.

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Whistleblowing Management