Whistleblowing

With Legislative Decree No. 24 of 10 March 2023, Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law (the so-called Whistleblowing Directive) was implemented in our system. In order to implement the provisions introduced by Legislative Decree no. 24/2023, the Company has established a Regulation that provides clear operational indications on the subject, recipients, methods of transmission and management of reports concerning "violations", as well as the protection measures provided for.

Who can file reports?
Reports may be sent, by way of example but not limited to, by: employees, self-employed workers, holders of a collaboration relationship, freelancers, consultants, trainees, suppliers, persons with functions of administration or control of the Company, such as Board members or members of the Board of Auditors.

What can be reported?
Reports, which should be as detailed as possible, must concern violations falling within the scope of Article 2 of Legislative Decree 24/2023. The legislation defines 'violations' as all conduct, acts or omissions that harm the public interest or the integrity of the public administration or private entity and that consist of administrative, accounting, civil or criminal offences, unlawful conduct relevant under Legislative Decree 231/01 or violations of organisation and Management and Control models; offences that fall within the scope of application of European Union or national acts, acts or omissions that harm the financial interests of the Union, acts or omissions concerning the internal market.

How to report?
Reports must be made by accessing the Whistleblowing platform accessible at the following link:
https://alba.wb.teseoerm.com/#/
The whistleblowing channel is to be used as a priority.
Please consult the Whistleblowing Regulation for more details on how to send reports.

Who receives the reports?
The management of the whistleblowing channel and the verification of the validity of the facts reported are entrusted to a Whistleblowing Committee external to the Company, which verifies the facts reported in accordance with the principles of objectivity and confidentiality, including the possible hearing of the whistleblower and any other persons who may report on the facts reported. To this end, the Committee may avail itself of the support and cooperation of external consultants or of the competent corporate structures.