Reporting of unlawful conduct pursuant to Legislative Decree 24/2023 (Whistleblowing)
The “platform” for reporting
Intercarta S.p.A. (hereinafter the “Company”) makes the Whistleblowing Platform (hereinafter the “Platform”) available to those who wish to report, in good faith, behaviors or events that may constitute violations of laws or regulations (national or European Union), and/or company procedures, or otherwise incompatible with ethical conduct.
Reports must be made to protect the public interest and the integrity of the Company.
The methods of transmitting the report
The Platform allows the Whistleblower, when reporting, to choose whether or not to disclose their identity.
Access to the Platform is managed in a log-free manner to prevent the identification of Whistleblower who wish to remain anonymous. In any case, the Whistleblower may supplement their personal details at a later time, if desired, through the Platform.
After logging in, the Whistleblower will be guided through a questionnaire that will allow them to provide, in written or oral form, the information characterizing the report (facts, context, any persons involved, etc.).
The Whistleblower also has the option, again through the Platform, to request a face-to-face meeting.
How to manage the report
Upon submission of the report, the Platform will issue the Whistleblower a unique identification code (hereinafter “receipt”). This number, known only to the Whistleblower, cannot be recovered if lost.
The receipt will be used by the Whistleblower to access their report, again through the Platform, to monitor its progress, add additional information to substantiate the report, add personal information, and ask or answer any questions for further information.
The Platform allows for a virtual conversation between the Whistleblower and the recipient, ensuring the necessary confidentiality and, at the Whistleblower’s discretion, anonymity.
Who manages the reporting?
The task of receiving and managing reports is entrusted to a Company Whistleblowing Committee, whose members are listed in the “Procedure for Reporting Misconduct – Whistleblowing Policy,” available at the bottom.
The Committee has its own Operating Regulations, which describe how it handles reports involving one of its members (so-called conflicts of interest).
An acknowledgement of receipt will be sent to the Whistleblower via the Platform within 7 days of the submission date.
Further information will then be provided via the Platform once the investigation into the reported event is complete, and in any case no later than 3 months later.
Protection and responsibility of the whistleblower
No retaliation or discrimination, direct or indirect, may be suffered against anyone who, in good faith, files a report. Furthermore, sanctions are provided for those who violate measures to protect the identity of the Whistleblower.
Where possible, sanctions are provided for the Whistleblower in the event of reports made with intent or gross negligence, or that prove to be false, unfounded, defamatory, or otherwise made with the sole purpose of harming the Company, the reported party, or the parties affected by the report.
The Company may also take appropriate legal action.
Protection of the reported person
A report is not sufficient to initiate any disciplinary action against the reported individual. If, following concrete evidence obtained regarding the report, we decide to proceed with an investigation, we may contact the reported individual, who will be guaranteed the right to provide any necessary clarification.
Recommendations
The Platform is intended for use by those who, in good faith and in accordance with ethical principles of integrity, report behavior that may violate laws and regulations or internal Company principles and procedures, of which they have become aware. Such reports are also accepted anonymously.
The Company will prosecute those who report in bad faith, with defamatory intent, or that do not reflect the proper spirit of collaboration with the company.
The protections afforded to the Whistleblower do not apply to disputes, claims, or requests related to the personal interests of the Whistleblower that pertain exclusively to their individual employment relationships, or to their employment relationships with superiors. Therefore, please DO NOT use the Platform for such issues.
In general, the Company encourages its employees to resolve any labor disputes, where possible, through dialogue, even informally, with their colleagues and/or their direct manager.
Likewise, please do not use the Platform for complaints, support requests, or other commercial inquiries. For these purposes, specific sections are available on the Company’s websites.
Reports must be made responsibly, be of interest to the common good, and fall within the types of non-compliance for which the system was implemented.
Please refrain from submitting reports that do not fall within the cases indicated above.
Privacy Policy
All reports are strictly confidential. Any personal data contained in the report will be processed in compliance with the personal data protection regulations and the technical and organizational measures adopted by the Company, pursuant to EU Regulation 2016/679 (GDPR). For more information, please consult the “Privacy Policy” section on the Whistleblowing Platform login page.
Useful Links
Whistleblowing procedure
Consult the Whistleblowing Policy for reporting unlawful conduct adopted by the Company.
Reporting platform
Go to the Whistleblowing Platform to submit a report of unlawful conduct or violations of laws and regulations.