Whistleblowing

In accordance with current whistleblowing regulations, Esseco provides information and guidelines in this section of the website on how to make reports.

DEFINITIONS

A whistleblower is the individual making the report.

This can include employees of the company, interns, collaborators, employees of suppliers and contractors, consultants, shareholders, and individuals performing administrative, control, supervision, or monitoring functions within the organization, reporting any misconduct or violations they become aware of.

Whistleblowing is the process aimed at encouraging reports and protecting the whistleblower due to its social function.

LEGAL SOURCE AND NATURE OF THE INSTITUTE

For more information on current whistleblowing regulations and specific application scenarios, we encourage you to refer to Legislative Decree no. 24 of March 10, 2023, and visit the dedicated page on the website of the National Anti-Corruption Authority (ANAC).

There is no exhaustive list of crimes or irregularities that can be the subject of whistleblowing. Reports concerning behaviors, risks, crimes, or irregularities, committed or attempted, to the detriment of public interest, public administration, or the company are considered relevant.

Possible misconduct or violations that can be reported include:

• Administrative, accounting, civil, or criminal offenses.
• Unlawful conduct relevant under Legislative Decree 231/2001 and company procedures.
• Offenses falling within the scope of EU or national acts related to public procurement, financial services, products and markets, anti-money laundering and counter-terrorism financing, product safety and compliance, transportation safety, environmental protection, radiation protection, nuclear safety, food and feed safety, and health and welfare of animals.
• Acts or omissions that harm the financial interests of the Union.
• Acts or omissions concerning the internal market.
• Acts or behaviors that undermine the purpose of provisions in Union acts.

Whistleblowing does not cover personal complaints by the reporter or claims/issues falling under the discipline of the employment relationship or relationships with superiors or colleagues, which should be referred to the Personnel Office and the Supervisory Body.

CONDITION FOR REPORTING

Reasonableness: At the time of reporting, the reporter must have a reasonable and well-founded belief that the information on reported violations, publicly disclosed or reported, is true and falls within the scope of the regulations.

Reports can be made in writing, potentially anonymously, through the use of the software platform https://esseco.segnalazioni.net/.

The internal manager responsible for reports will maintain communication with the reporter and properly handle received reports.

Specifically, upon receiving a report, an assessment will be conducted to verify the validity of the circumstances presented, respecting the principles of impartiality and confidentiality. This may involve activities such as a personal hearing of the whistleblower and any other individuals who can provide information on the reported incidents.

If the report lacks specificity and/or verifiability, and the reporter cannot be reached for necessary clarifications, the manager archives the report.

If the content of the report is confirmed, the manager delegates the definition of any necessary measures to the competent functions.

The reporter will receive feedback on the progress of the report within 3 months of its receipt.