Management of whistleblowing reports

Eldes S.r.l. adopts a process for the receipt, analysis and processing of reports (including anonymous ones) that complies with the regulatory changes introduced by Legislative Decree No. 24 of 10 March 2023 implementing Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law and laying down provisions concerning the protection of persons who report breaches of national laws (so-called “Whistleblowing Decree“).

For sending and managing reports, Eldes S.r.l. implements a dedicated IT platform, which is the preferred channel for sending reports.

If you want to make a report to Eldes, click here: https://eldesradar.integrityline.com

Who can report

The following can make a report

• employees, self-employed workers, holders of a collaboration relationship, volunteers and trainees, including unpaid ones, who work for Eldes S.r.l;
• workers or collaborators who work for entities that provide goods or services or that carry out works for third parties; freelancers and consultants who work for Eldes S.r.l.; shareholders and people of Eldes S.r.l. with functions of administration, management, control, supervision or representation.

These individuals shall report information on violations they have become aware of within their work context.

Reports may also be made:

• when the legal relationship has not yet started, if information on breaches has been acquired during the selection process or in other pre-contractual stages;
• during the probationary period;
• after termination of the legal relationship if information on breaches was acquired during the course of the relationship.

Eldes S.r.l. hopes that the identity of the reporter is made explicit in the reports, whose confidentiality is guaranteed in compliance with current legislation, so as to facilitate the verification of the facts reported and inform the reporter on the outcome of the investigations carried out. Reports in anonymous form are in any case admissible.

What to report

Information on violations concerning facts (of any nature, including mere omissions) that may constitute violations of the Model 231 of Eldes S.r.l. and/or the Code of Ethics and/or internal company regulations. Violations with a different subject matter will however be taken into account and analysed.

Reports must concern facts of which the reporter has knowledge, the reporter himself/herself having reasonable grounds to believe that the information reported is true at the time of reporting.

Reports must be made in a timely manner with respect to the knowledge of the facts so as to make their verification concretely possible.

Limits to reporting

The following do not constitute so-called whistleblowing reports: objections, claims or requests linked to a personal interest of the reporter that relate exclusively to his/her individual employment relationship, or inherent to his/her relationship with hierarchically superior figures. The report may not consist of complaints relating to activities of a commercial nature (e.g. complaints).

The report must be made in conscience and good faith and must not take on insulting tones or contain personal insults or moral judgments designed to offend or harm the personal and/or professional honour and/or decorum of the person or persons to whom the facts reported are allegedly attributed. It is specified that any report made with malice or serious misconduct may be sanctioned from a disciplinary point of view and also expose the person making the report to criminal liability (e.g. for slander or defamation) and civil liability.

The reporter must have ‘reasonable grounds’ to believe that the information transmitted and shared is true.

Internal reporting channels

Eldes S.r.l. provides the following reporting channels:

1. IT platform accessible from https://eldesradar.integrityline.com;
2. Voice messaging and morphing system, through the IT platform accessible from https://eldesradar.integrityline.com
3. Verbally, by requesting a direct meeting with the Reporting Manager.

The IT platform is the preferred tool for sending and managing reports.

External Reporting Channels

The legislator has provided for external reporting channels, which are different from the internal ones that each company has, and which can be activated in limited and specific circumstances:

• external (National Anti-Corruption Authority, so-called ANAC)
• public disclosure
• report to the Judicial Authority

How to choose the reporting channel?

Primarily, reporters are encouraged to use the internal channel, and only under certain conditions they can make an external report or public disclosure.

For any additional information on Eldes S.r.l. reporting system (e.g., who manages the reports), it is recommended to consult the dedicated company policy before making a report, along with the Privacy Policy, available here: https://eldesradar.integrityline.com