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INTRODUCTION

TRANCERIE EMILIANE S.p.A.’ S VISION 

The alterations of the economic, social and environmental scenario require an update of the Code of Ethics, capable of guiding evolution procedures and development. TRANCERIE EMILIANE S.p.A. is aware that authority in a company must be identified, in addition to the competence of its employees and the high quality of the service provided to customers, but also by the attention paid to the needs of the community.  The principles that have always inspired the work in our company are formally collected in a Code of Ethics in the belief that reliability is built daily by respecting regulations and valorising people.

This Code of Ethics therefore represents a distinctive and identifying element towards the marketplace and third parties, where knowledge and sharing, of which, required of all those who work or collaborate in our firm, constitute the foundation of our business and the first step that contributes to the pursuit of our vision.

TRANCERIE EMILIANE S.p.A.’s objective is therefore to pursue excellence in our field of work, to obtain satisfaction and assure an added value for employees, for customers and, in general, for the community through a sustainable development, preserving the environment and the security of the people involved by consistency of a respectful conduct of the social ethics.

 

PURPOSE AND RECIPIENTS

The current Code of Ethics (hereinafter, the “Code”) illustrates the set of ethical and moral principles that are at TRANCERIE EMILIANE S.P.A. (hereinafter, “Company”) as well as the lines of conduct adopted by the Company both within its own business (in the relationships among employees) and outside (in the relationships with institutions, suppliers, customers, business partners, political organisations, unions as well as news media (hereinafter, “stakeholders”) and this both in Italy and abroad.

Compliance with these principles is of fundamental importance to pursue and achieve the corporate mission, and to guarantee TRANCERIE EMILIANE S.p.A.’s reputation in the socio-economic context in which it operates.

 Preliminarily, it should be noted that TRANCERIE EMILIANE S.p.A. firmly believes that every activity must be carried out ethically, recognizing itself in the principle established by art. 41 of the Constitution, according to which the private economic initiative “cannot take place in conflict with social utility or in such a way as to cause damage to security, freedom, or human dignity.” The present Code is binding for both directors and employees of TRANCERIE EMILIANE S.p.A. as well as for all those who work and collaborate permanently, or on a fixed-term basis, on behalf of the Company. (hereinafter, “Recipients”)

The Code will be widely disseminated within the internal governance structure, and widely communicated externally, including through its website.  TRANCERIE EMILIANE S.p.A. also undertakes to adopt any further provision so that the principles and provisions of the code can be promptly disclosed and applied.

 

GENERAL PRINCIPLES

The conduct of recipients, at all corporate levels, is based on the principles of legality, fairness, without discrimination, confidentiality, diligence, and loyalty.

 

Environment

TRANCERIE EMILIANE S.p.A. considers the natural capital, i.e., the environmental resources and the services provided by ecosystems, to be a fundamental asset for the balanced development of businesses and territories. Eco-efficiency becomes success and competitiveness in the comparison taking place on international markets; TRANCERIE EMILIANE S.p.A., through careful management, cannot only reduce its impacts, but also have a regenerative effect on the environment. TRANCERIE EMILIANE S.p.A. therefore promotes righteous practices, for example, energy saving* in order to promote prevention, recycling and recovery of resources and a conscious protection and enhancement of ecosystems.

*LEGISLATIVE DECREE November 8, 2021, n.199

Implementation of Directive (EU) 2018/2001 of the European Parliament and of the Council of December 11, 2018 on the promotion of the use of energy from renewable sources. (21G00214)

Note:  Entry into force of the provision:  15/12/2021 (last update to the deed published on 21/04/2023)

 

Legality

TRANCERIE EMILIANE S.p.A. operates in full compliance with the law and current Code.

All Recipients are therefore required to comply with all applicable regulations and to constantly update themselves on legislative developments, also making use of the training opportunities offered by TRANCERIE EMILIANE S.p.A.

The Company considers the transparency of financial statements and accounting to be a fundamental principle for managing business and for the protection of its reputation.

 

Fairness and honesty

Fairness and moral integrity are an unchanging duty for all Recipients.

The Recipients are required not to establish any privileged relationships with third parties, which is the result of external solicitations aimed at obtaining improper advantages.

In carrying out their activities, the Recipients are required not to accept donations, favors or benefits of any kind and, in general, not to accept any counterpart in order to improperly grant advantages to third parties.

In turn, the Recipients must not make donations of money or goods to third parties or in any case offer illicit benefits or favors of any kind (except for objects of modest value or commercial courtesy gifts authorized by the Company) in connection with activities carried out for TRANCERIE EMILIANE S.p.A.

 

Value of human resources

The directors, auditors, employees and collaborators of TRANCERIE EMILIANE S.p.A. are an indispensable factor for their affirmation and continuous improvement in the reference sector. For this reason, TRANCERIE EMILIANE S.p.A. protects and promotes the value of human resources in order to improve and increase the assets and competitiveness of the skills possessed by each of them. TRANCERIE EMILIANE S.p.A. guarantees the physical and moral integrity of human resources and working conditions that respect individual dignity, and safe and healthy workplaces.

 

Equity of hierarchical relationships

In the signing and management of relationships that imply the establishment of hierarchical relationships, especially with its employees and collaborators, TRANCERIE EMILIANE S.p.A. is committed to ensure that authority is employed fairly and correctly, avoiding any infringement. TRANCERIE EMILIANE S.p.A. especially guarantees that authority does not turn into harmful power to the collaborator’s dignity and independence, and that the choices of work organisation always safeguard the value of the collaborators.

 

Responsibility

Each recipient of the Corporate Code of Ethics carries out their work and their services with diligence, efficiency, fairness, also complying in writing as well as through professional conduct and written and verbal reports suitable with civil life, making the best use of the tools and time available, and taking on responsibilities associated with obligations.

 

Communication

TRANCERIE EMILIANE S.p.A. informs all Recipients of the provisions and application of the Company Code of Ethics, recommending its observance. 

In particular, it propagates the Code in question to the Recipients, encourages interpretation and clarification of the provisions contained therein, verifies effective compliance, updates the provisions with regard to the needs that arise from time to time.

The corporate Code of Ethics is disclosed by publication on the website.

 

Internal control

In relation to internal control, TRANCERIE EMILIANE S.p.A. ensures: (i) the adequacy of the various corporate procedures in terms of effectiveness, efficiency, and affordability. (ii) the reliability and correctness of accounting records and the safeguarding of company assets. (iii) the compliance of operational obligations with internal and external regulations.

 

Non-discrimination

In the relations with Stakeholders and in particular in the selection and management of personnel, in work organisation, in the choice, selection and management of suppliers and in relations with Bodies and Institutions, the Company avoids and repudiates any discrimination concerning the age, gender, race, sexual orientation, state of health, political and trade union opinions, religion, culture and nationality of its interlocutors. TRANCERIE EMILIANE S.p.A., concurrently, favors integration, promoting intercultural dialogue, protecting, and defending the rights of minorities and vulnerable subjects.

 

Confidentiality

TRANCERIE EMILIANE S.p.A. undertakes to ensure the protection and confidentiality of the personal data of the Recipients and Stakeholders, in compliance with all applicable regulations on the protection of personal data.

The Recipients are required not to use confidential information, acquired by reason of their work activity, for purposes unrelated to the exercise of this activity, and in any case to always act in compliance with the confidentiality obligations taken on by the Company towards all Stakeholders. 

Recipients are required to maintain the utmost confidentiality on documents suitable for revealing know-how, personal information, commercial information, corporate procedures.

 

Diligence

The relationship between TRANCERIE EMILIANE S.p.A. and its employees is based on mutual trust:  employees are therefore required to work to promote the interest of the company, in compliance with the values set out in this Code.

Recipients must refrain from any activity that may conflict with the interests of TRANCERIE EMILIANE S.p.A. renouncing the pursuit of personal interests in conflict with the legitimate interests of the Company. 

In cases where a possibility of the existence of a conflict of interest can be represented, the Recipients are required to contact, immediately, their hierarchical superior so that the company can evaluate, and possibly authorize, the potentially conflicting activity.

In cases of violation, the Company will adopt all suitable measures to put an end to the conflict of interest, reserving the right to act for its own protection.

 

Loyalty

TRANCERIE EMILIANE S.p.A. and the Recipients undertake to implement fair competition, in compliance with national and community legislation, in the awareness that virtuous competition constitutes a beneficial incentive for innovation and development processes, and protects the interests of consumers and the community.

 

RELATIONSHIPS WITH EMPLOYEES AND COLLABORATORS 

Personnel selection

The evaluation and selection of personnel are decided according to fairness and transparency, respecting equal opportunities in order to combine the needs of TRANCERIE EMILIANE S.p.A. using professional profiles, ambitions and expectations of the candidates.  The Company undertakes to adopt any useful measure to avoid any form of favoritism in the personnel selection process using objective and merit-based criteria, respecting the dignity of the candidates while maintaining the interest of rendition for the company.  The staff hired, also through the implementation of this code, receives clear and correct information about the roles, responsibilities rights and duties of the parties.

 

Personnel management

TRANCERIE EMILIANE S.p.A. protects and enhances its human resources, committing itself to maintain constant the conditions necessary for the professional growth, the knowledge and skills of each person, carrying out the appropriate training for professional updating and any initiative aimed at pursuing this purpose. 

TRANCERIE EMILIANE S.p.A. promotes participation of workers in the life of the company, providing participatory tools capable of collecting the opinion and suggestions of workers, ensuring their widest participation. 

Without prejudice to the utmost availability towards the Company, no worker can be forced to perform tasks, services or favors that are not due based on their employment contract and their role within the company. 

The Company is firmly committed to combating episodes of mobbing, stalking, psychological violence and any behavior that is discriminatory or harmful to the dignity of the person inside and outside the company premises.

Relations between employees must take place with loyalty, fairness and mutual respect, in observance of the values of civil coexistence and personal freedom.

 

WORK ENVIRONMENT

TRANCERIE EMILIANE S.p.A. undertakes to propagate and consolidate a culture of safety, developing awareness of risks, compliance with current legislation, promoting responsible behavior on the part of everyone; moreover, it works to maintain, above all with preventive actions, the health and safety of workers, as well as the interests of other stakeholders.

Objective of TRANCERIE EMILIANE S.p.A. is to protect human, capital and financial resources, constantly seeking the necessary synergies, not only internally, but also with suppliers, companies and customers involved.

To this end, TRANCERIE EMILIANE S.p.A. carries out interventions of technical and organisational nature through:

- a constant analysis of the risk and of the criticality of the processes and resources to be protected;

- a continuous improvement of the prevention activity;

- the prompt preparation/updating of necessary measures and means;

- the adoption of the best technologies;

- the control and updating of work methods;

- the contribution of training and communication interventions.

TRANCERIE EMILIANE S.p.A., in compliance with the provisions of the applicable safety legislation, for the aforementioned purposes, inspires its conduct on the following principles:

- elimination of risks and, where this is not possible, their reduction to a minimum;

- assessment of risks that cannot be avoided;

- reduction of risks at source;

- compliance with ergonomic principles in the design of workplaces and the choice of work equipment, and work and production methods; with constant updates of the evolution of technique on the subject;

- planning of prevention, in the logic of creating a coherent complex that integrates technique, work organisation, working conditions, social relations and the influence of factors of the work environment;

- continuous training on prevention and safety.

These principles are employed by the company to take the necessary measures for the protection of workers’ health and safety, including the prevention of occupational risks, information and training, as well as the preparation of an organisation and the necessary means.

The entire company, both at top and operational levels, especially when decisions or choices have to be made, and subsequently, when they have to be implemented, complies with these principles.

 

Integrity and protection of the person

TRANCERIE EMILIANE S.p.A. undertakes to protect the moral integrity of its collaborators, guaranteeing the right to working conditions that respect the dignity of the person.

For this reason, the Company safeguards workers from acts of psychological violence and opposes any attitude or behavior that is discriminatory or harmful to the person, their beliefs and preferences (for example, in the case of insults, threats, isolation or excessive intrusiveness, professional limitations).

Sexual harassment is not permitted and behaviors or speeches that may disturb the sensitivity of the person must be avoided.  TRANCERIE EMILIANE S.p.A.’S collaborators, who believe that they have been subjected to harassment or have been discriminated against for reasons related to age, sex, sexuality, race, state of health, nationality, political opinions and religious beliefs, can report the incident to the President or Chief Executive Officer of TRANCERIE EMILIANE S.p.A., who will assess the effective violation of the Corporate Code of Ethics without prejudice to the possibility of resorting to the procedure for reporting violations of corporate rules and unethical behavior (whistleblowing). 

Inequalities are not considered discrimination if justified or justifiable on the bases of objective criteria.

 

Confidentiality and privacy

The information, data, knowledge acquired, processed and managed by employees and/or collaborators in while working must remain strictly confidential and suitably protected and cannot be used, communicated and disclosed, both internally and externally of TRANCERIE EMILIANE S.p.A., unless in compliance with current legislation and company procedures.

Confidential information, to be codified as the exclusive property of TRANCERIE EMILIANE S.p.A., is by way of example:

  • business, strategic, economic/financial, accounting, commercial, managerial, operational plans;
  • projects and investments;
  • data related to personnel such as absences, attendance, vacation, illnesses and salaries;
  • the corporate parameters of performance and productivity;
  • corporate agreements, commercial agreements and contracts, company documents;
  • the know-how related to production, development and marketing of products, services, processes and patents;
  • accounting, financial and economic data before publication;
  • company manuals;
  • databases related to suppliers, customers, and employees.

TRANCERIE EMILIANE S.p.A.’s collaborators must in any case keep any other information confidential, the dissemination of which could cause damage to the same.

In dealing with such data and information, the staff must pay the utmost attention and confidentiality, avoiding with their behavior to reveal information belonging to TRANCERIE EMILIANE S.P.A. and not yet public towards both colleagues and third parties.

 

BUSINESS MANAGEMENT

TRANCERIE EMILIANE S.p.A. believes that efficient management and a culture of control are essential elements for achieving the objectives.

Recipients are required to strictly comply with the company’s internal procedures and instructions.

Recipients must act according to their respective authorization profiles and must keep all appropriate documentation to keep track the actions taken on behalf of the company.

 

Quality Management

Quality is fundamental to our activities. It is expected by the customers of TRANCERIE EMILIANE S.p.A., the company demands it of itself, on its way to achieving excellence.

The Company policy is to place customer expectations at the core of our activities.

Customer satisfaction and loyalty to our company and products are the prime indicators of our success, and our main goal. The company policy is to follow a constantly evolving production and commercial strategy capable of obtaining growing economic results both from an economic point of view and from the point of view of customer satisfaction, offering a wide range of products, both standard (destined for the market of  electric motors and transformers), and OEM (destined for specific customers), in line with the most recent technological innovations.

For this reason, the Management of TRANCERIE EMILIANE S.p.A. has arranged for the implementation of a Quality Management System according to the methods set out in the Quality Manual in compliance with international reference standards.  It has set up the Quality Management function reporting directly to it  and pursues the continuous improvement of the effectiveness of its Quality Management System by committing itself to pursue the following general concepts:

TRANCERIE EMILIANE S.p.A.’s Quality Management System is based on the following principles:

  • compliance with laws in force and with the reference regulations on quality, safety and the environment;
  • empowerment of personnel involvement and motivation regarding quality issues in compliance with customer needs;
  • defect prevention;
  • continuous quality improvement, by monitoring procedure performance by implementing, where necessary, appropriate improvement actions;
  • measurement of the adequacy of compliance and effectiveness of the QMS through the acquisition of objective data, internal and external audits, as well as customer satisfaction;
  • availability and visibility of data records that constitute objective proof of product conformity.

 

Accounting records and economic and financial information – disclosure

TRANCERIE EMILIANE S.p.A. personnel, in carrying out their work and within the scope of their skills and responsibilities, must record and process data and information with accuracy, precision and completeness.

TRANCERIE EMILIANE S.p.A.’s accounting, economic and financial records and evidence instilled by these values, reflecting exactly described in the supporting documentation.

Accounting entries, economic and financial information should not be transmitted or disclosed to third parties without proper authorization from the competent corporate function.  For this purpose, TRANCERIE EMILIANE S.p.A. has implemented and maintains active and updated-through its internal structure that governs the information systems- the functions of the operating systems and company applications aimed at preventing the unauthorized disclosure and distortion of company data.  Employees who are aware of possible omissions, forgeries, alterations in accounting records and/or related documents, promptly inform their direct manager, without prejudice to the possibility of resorting to the procedure for reporting violations of company rules and unethical behavior (whistleblowing).

 

Conflict of interest

Directors, auditors, employees and collaborators of TRANCERIE EMILIANE S.p.A. avoid situations in which conflicts of interests may arise and to refrain from personally taking advantage of business opportunities of which they have become aware in the course of carrying out their duties.

Specifically forbidden to:

-accept money or favors from people or companies that have or intend to have business relations with TRANCERIE EMILIANE S.p.A.

-make available to third parties, by an employee, confidential information obtained in the performance of one’s duties or use it for one’s own personal benefit.  If a conflict of interest occurs, or there are serious reasons of convenience, the person involved is required to notify his/her direct manager, who informs the Chairman or the managing Director of TRANCERIE EMILIANE S.p.A. who, possibly, with the support and help of the other members of the Board of Directors and the Board of Statutory Auditors, assesses its actual existence case-by-case.

The same collaborator is also required to provide information about the tasks carried out outside working hours in the event that these may appear to be in conflict of interest with TRANCERIE EMILIANE S.p.A.

 

Protection of company assets and compliance with IT policy

Each collaborator works diligently to protect corporate assets, through responsible behavior and in line with the operating procedures set up to manage their use.

In particular, each collaborator:

- uses the entrusted assets scrupulously and diligently

-avoids improper use of company assets/equipment that could cause damage or reduce efficiency, or in any case be contrary to the company’s interests.

Each collaborator is responsible for protecting the resources entrusted to him. He has the duty to inform his direct manager promptly of any threats or harmful events for TRANCERIE EMILIANE S.p.A. 

The protection and conservation of these assets constitutes a fundamental value for safeguarding TRANCERIE EMILIANE S.p.A.’s interests and it is in everyone’s responsibility (in carrying out business activities), not only to protect these assets, but to prevent their fraudulent or improper use.  The use of corporate assets must be functional and exclusive to the performance of corporate activities or for authorized department purposes.

TRANCERIE EMILIANE S.p.A. reserves the right to prevent misuse of its assets/equipment through use of accounting systems, financial control reporting and prevention analysis, in compliance with applicable law provisions (law on privacy, statute of workers etc.)

With reference to computer applications, each collaborator:

- Scrupulously adopts provisions of corporate security policies, in order not to compromise the functionality and protection of the IT systems

- Does not send threatening and abusive e-mails and does not use improper language, does not say inappropriate comments that may offend a person and/or damage the corporate image

- Does not browse websites with indecent and offensive content

Each collaborator is also required not to reveal passwords or access codes in his/her possession for any reason whatsoever.

Each collaborator must not access to other people’s computer systems without authorization; and must not partake in behavior aimed in any way at destroying or damaging computer systems or information.

In general, each collaborator respects the principles of correctness, integrity, appropriateness and privacy with the use of IT applications in compliance with TRANCERIE EMILIANE S.p.A.’s policy.

All behaviors that in any way constitute violations of the provisions of the policy adapted by legislation and TRANCERIE EMILIANE S.p.A., must be avoided.

When returning company equipment (such as, personal computers, I pads, mobile phones) containing data and information acquired or uploaded in any IT and/or telephone device for work purposes must be returned, contextually with written declaration of access passwords, turned on, functional and containing all the data information collected and processed therein.  All data are exclusively proprietary and reserved to the Company with clear violation of forwarding or disclosure, in any form, even partially, to unauthorized third parties.

Where these instruments contain personal data and information, their download can only take place in the presence of a technician appointed by TRANCERIE EMILIANE S.p.A., who supervises the procedure.

 

Communication

TRANCERIE EMILIANE S.p.A. accounts for suitable communication tools available to stakeholders through which they can interact with the company to forward requests, ask for clarification or make complaints.  TRANCERIE EMILIANE S.p.A. promotes effective corporate communication capable of direct contact with civil society, in order to implement the requests, demands and needs of the community and to extend its values and goals.

The information disclosed to stakeholders is complete and thorough so recipients are able to take on correct and conscious decisions.

TRANCERIE EMILIANE S.p.A.’s promotes and respects ethical values, protecting minors and disavowing vulgar or offensive messages.

 

EXTERNAL RELATIONSHIPS

Relationships with authority and public administration

Relationships with authorities and public administrations must be built by maximum clarity, transparency and collaboration, in full compliance with the law and according to the highest moral and professional standards. In relations with public officials, public service officers, and public administration in general, the authorised recipients will abide by the highest levels of correctness and integrity, refraining from any form of pressure, explicit or not, aimed at obtaining any undue advantage for themselves or for TRANCERIE EMILIANE S.p.A.

For this reason, authorized recipients will be required to abide by the requirements of this Code, as well as, the legislative requirements ordered by the management of TRANCERIE EMILIANE S.p.A.

 

Relationships with political organisations and trade unions

TRANCERIE EMILIANE S.p.A. does not favor or discriminate any political organisation or trade union. The Company refrains from providing any undue contributions in any form to parties, trade unions or other social associations.

Recipients are required to refrain from any direct, indirect or boasting on politicians or trade union representatives.

 

Relationships with customers and suppliers

Recipients relate to third parties with courtesy, competence and professionality, in the belief that the company’s image, reputation, and consequently the achievement of corporate objectives, depend on their conduct.  Specifically, recipients must refrain from any form of unfair, deceptive behavior that could lead customers or suppliers to relay on unfounded facts or circumstances.

Recipients are required to work regularly to offer punctual and high-quality services to customers, trying to limit any form of disservice or delay in order to maximize customer service and satisfaction.  Relations with suppliers are based on loyalty, decency, fairness and transparency.  The choice of suppliers is made by objective economic criteria, opportunity and efficiency. The choice of suppliers is merely subjective and personal, in any case, by virtue of conflicting interests with those of the Company are excluded.

Recipients must implement all possible survey so that suppliers and customers are also able to comply with the fundamental ethical principles in reference to this Code.

 

INTERNAL CONTROL SYSTEM

Compliance with the provisions of this code entrusted to prudent, reasonable and careful supervision of each recipients, within the context of their respective roles and duties within the company.

All recipients should report to their direct superiors any facts and circumstances potentially in conflict with the principles and provisions of this code. TRANCERIE EMILIANE S.p.A.’s management and authority set up for this purpose, adopt all necessary measures to put an end to violations, being able to resort to any disciplinary measure in compliance with the law and workers’ rights, including trade union rights.

 

GUIDELINES TO THE SANCTION SYSTEM

The internal control system is oriented towards the adaption of equipment and methods aimed at contrasting potential corporate risks, in order to ensure compliance not only with the law, but also with internal regulations and procedures.

In fact, the violation of principles established in the code and in the procedures stated in internal control, compromises the relationship of trust among the company and its directors, employees, consultants, collaborators, customers, suppliers, commercial and financial partners.

Such violations will therefore be immediately prosecuted by TRANCERIE EMILIANE S.p.A. in an incisive and timely manner, through the adoption of adequate and proportionate disciplinary measures. The effects of violations of the Code of Ethics and internal registry must be taken into consideration by all those who, for whatever reason, maintain relations with TRANCERIE EMILIANE S.p.A.  Depending on the seriousness of the conduct by the subject involved in illegal activities stated by the Code, TRANCERIE EMILIANE S.p.A. will promptly attain appropriate measures regardless of any criminal prosecution by judicial authority.

Without preconception to the above, conduct in violation of the Code of Ethics constitutes:

*Serious non-compliance for employees (workers, employees, managers and executives), with sanctions, applied according to the seriousness of the situation, provided for by the CCNL (National Collective Bargaining Agreement).

*Cause of immediate termination of relations, in most serious cases, for consultants.

*Cause of immediate termination of relations, in most serious cases, for suppliers, contractors and subcontractors.

The identification and application of sanctions will always take into account proportion and adequacy in relation to the alleged violation.  In the above-mentioned hypotheses, TRANCERIE EMILIANE S.p.A., also reserves the right to take all actions it deems appropriate for damage compensation subjected to in result of violation of the Code of Ethics.

 

REPORT OF VIOLATION OF COMPANY RULES AND UNETHICAL BEHAVIOR (“WHISTLEBLOWING”)

According to Legislative Decree 24/2023; in a company with more than 50 employed workers, violations of the Code of Ethics may be reported by any person of interest.  In the event of an alleged violation of regulations referred to Law 231/01, the reporting must be done through a specific designated email address judged accordingly by the Supervisory Body.  Reports must be based on precise, and concordant factual  elements, of which the recipients concerned have become aware of due to work function or performance. The procedures for reporting and verifying of violations, even in the interest of truthfulness, are based on the criteria of privacy and protection of confidentiality, in order to prevent retaliation of any kind against the author of the report, but also in order to guarantee the verification of the effective reality of facts. The adoption of discriminatory measures toward subjects who make detailed reports of unlawful conduct, related to Legislative Decree 24/2023, based on precise and concordant factual elements, of which they have become aware according to the functions performed, may be disclosed to the National Labor Inspectorate, for measures within its competence, not only by the reporting party but also by the Trade Union. Even if the facts reported should turn out to be unfounded and/or inconsistent, based upon assessments and investigations carried out, the whistleblower who disclosed information in good faith, will not undergo punitive action. Vice versa, when reports transmitted exclusively for the purpose of damaging or otherwise causing harm to the person reported, or there is an abuse of the reporting instrument referred here, it will be withholding responsibility for the whistleblower, in disciplinary proceedings and in other competent offices, especially if the ground of what has been reported, and the instrumental and voluntary falsehood of accusations, findings, censures etc. are ascertained.  All reports attained by authority and supervisors are managed in absolute confidentiality, and under penalty of revocation of the mandate of the members of the same entity.

 

13th September 2023     

The Management

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