Whistleblowing policy

The term “whistleblowing” refers to a report made by a person who, in the performance of their duties within their organisation, becomes aware of an unlawful act or event that may constitute a crime or other irregular conduct or a violation of internal rules.

Following a long regulatory process, the recent Legislative Decree No. 24 of 10 March 2023 (the so-called “whistleblowing decree”) has implemented in Italy the EU Directive 2019/1937 concerning whistleblowing, thereby modifying the regulatory framework on this matter. This Directive provides for the protection of those who report breaches of national or European law which come to their attention in their working environment, including in the private sector.

As proviDed for by the aforementioned decree, the violations that can be reported are:

Unlawful conduct pursuant to Legislative Decree 231/2001, or specific breaches of the organisation and management model that may have been adopted, or the internal regulations and code of ethics of the Company.

Offences relating to the following areas: public procurement; protection of privacy and security of networks and information systems; environmental protection; public health; consumer protection; safety and compliance of products; financial services, products and markets; and prevention of money laundering and terrorism financing;

Acts or omissions detrimental to the financial interests of the Union (i.e. “revenues, expenditures and assets covered by the budget of the European Union and those covered by the budgets of the institutions, bodies, offices and agencies and the budgets managed and monitored by them”, pursuant to Art. 2 of EU Regulation No 883/2013); Acts or omissions relating to the internal market, including violations of EU competition and state aid rules, as well as corporate tax.

Please note that complaints, claims or requests are not covered by the whistleblowing policy when they are related to a personal interest of the whistleblower or of the person filing a complaint to the judicial or tax authorities that relates exclusively to their individual employment relationship, or to their relationship with supervisors or line managers.

As the main whistleblowing tool required by law, the IPI Group has adopted an IT platform that, in addition to guaranteeing the proper processing of personal data, complies with the provisions of the GDPR.

The dedicated platform is the following: Whistleblower Software.

Reports sent to the Designated Officer through this platform therefore guarantee the confidentiality of the whistleblower.

In this regard, reference is made to the notice pursuant to Art. 13 of Legislative Decree of 30 June 2003 adopted by the IPI Group.