Whistleblowing

THE WHISTLEBLOWING VIOLATION REPORTING SYSTEM

Rinascimento SCF S.r.l considers Whistleblowing an important tool to prevent, avoid, or stop potentially harmful unlawful actions while promoting transparency and integrity.

WHO CAN MAKE A REPORT:

In line with the provisions of Legislative Decree 24/2023, the range of individuals who can submit a Whistleblowing report has been expanded:

  • All employees of the company;
  • Self-employed workers and individuals with a collaboration agreement, workers or collaborators of suppliers, freelancers, and consultants working with the company;
  • Volunteers and interns (both paid and unpaid);
  • Shareholders and individuals with administrative, management, control, oversight, or representation functions;
  • Job applicants;
  • Trainees;
  • Former workers.

In line with the provisions of external regulations, the Company ensures the confidentiality of the whistleblower’s personal data, as well as protection against any retaliatory actions of a professional, contractual, or organizational nature, and against any act or omission that could constitute a form of retaliation, penalty, or direct or indirect discrimination against them for reasons directly or indirectly related to the report made. Protective measures are also extended to third parties involved.

TYPES OF IRREGULARITIES THAT CAN BE REPORTED*:

The new Decree defines and expands the types of violations that can be reported, covering behaviors, acts, or omissions that harm the public interest or the integrity of a private entity, which the whistleblower becomes aware of in the work context. These may include administrative, accounting, civil, or criminal violations, etc.

Examples of the primary rules whose violation may be subject to reporting are reported below:

  • Rules governing financial activities;
  • Regulations on anti-money laundering and counter-terrorism financing;
  • Organizational and Management Model pursuant to Legislative Decree 231/01;
  • Rules, laws, regulations, Codes of Conduct, or other company provisions punishable through disciplinary measures.

*The Whistleblowing channel is not intended for submitting complaints or commercial inquiries, nor for disputes regarding employment relationships.

HOW TO MAKE A REPORT:

Internal Channels of the Company:

The Company has not activated internal reporting channels.

External Channels:

Highlighting the importance of using internal channels, it is possible for the whistleblower to make an external report to the National Anti-Corruption Authority (ANAC), following the procedures outlined on the institution’s official website, if, at the time of submission, one of the following conditions applies:

  • The activation of an internal reporting channel is not mandatory in the specific work context, or the internal channel is inactive, non-operational, or non-compliant with external regulations;
  • The whistleblower has already submitted an internal report in accordance with the applicable external regulations, but no action has been taken;
  • The whistleblower has reasonable grounds to believe that making an internal report would not lead to effective action or could expose them to the risk of retaliation;
  • The whistleblower has reasonable grounds to believe that the violation may constitute an imminent or clear danger to public interest.