Whistleblowing

Whistleblowing is a key tool for corporate compliance, whereby employees of a company or third parties (for example, a supplier or a customer) can report, in a confidential and protected manner, any wrongdoings they become aware of in their job.

Reporting channel

The whistleblowing internal reporting channel can be used to report suspicions concerning behaviours or wrongdoings at our company. The goal of our whistleblowing structure is to provide a better opportunity of disclosing various types of misconduct and to ensure higher protection to the whistleblower. Whistleblowers are protected from any retaliation.

What should be reported?

Whistleblowing is the reporting by a worker that, while performing his or her job, becomes aware of situations, facts or circumstances that can reasonably lead to believe that any wrongdoing or offence has taken place.

When reporting it, there must be valid reasons to believe that the provided information is true at the time it is reported. The purpose of the whistleblowing reporting channel is to prevent and detect frauds and corruption/bribery, illegal activities and noncompliance with the law. By way of example and not limited to

• Financial fraud and criminal offences
• Bribery and corruption
• Environmental risks or Health and Safety risks
• Wilful violations of the law.

The reported misconduct does not have to be present or underway and whistleblowers may also report misconducts occurred in the past. This service does not have the purpose of expressing grievances about work conditions, the organization or management or conflicts at work. Any reported misconducts that concern exclusively the whistleblower or his/her work situation are not generally considered a whistleblowing case.

Reporting

Any wrongdoings must be reported to this certified e.mail address (Italian acronym PEC): felinese.whistleblowing@legalmail.it and the information listed below must be reported

• The type of wrongdoing that you want to report.
• Where it took place.
• When it it took place. Please, specify the date and time and whether the wrongdoing is recurring.
• Documents in any formats, if accessible. If the relevant documents are not accessible, but you know that they exist, please specify the type of documents and where they can be found.
• The details of any other actions that has been taken concerning the wrongdoing.

Please, note! First of all, it is pointed out that all personal data processing subsequent to whistleblowing are subject to the statutory legislation on personal data processing. No personal data that are not strictly relevant to the reported wrongdoing must be sent. However, should you send any such data, we shall be entitled to delete then without informing you.

Anonymous or confidential reporting

You have the right to choose between anonymous reporting and giving your name and contract details in message reporting the wrongdoing. If you opt for anonymous reporting, your identity shall remain fully hidden, unless you voluntary provide your personal data. you are under no obligation to disclose your personal data. If you opt for confidential reporting, you must give your name and, if you want, your contact details. This option may be required by some organizations and will facilitate the appropriate investigations and follow-up actions. Appropriate measures shall be adopted to protect your identity and the information you provide, in compliance with the laws on the protection of whistleblowers.