Whistleblower system

Transparency and Accountability

Welcome to our Whistleblower section, an important tool reflecting our commitment to transparency, integrity and responsible management of business operations. We recognise that a company's success is closely linked to a culture of openness and readiness to deal with unethical behaviour.

The Whistleblower channel was established with the aim of creating an environment in which employees, customers, suppliers and other stakeholders feel free to report any suspicious or non-compliant behaviour.

Confidentiality of reports is our top priority. All reports through the Whistleblower channel will be treated confidentially, and we guarantee that whistleblowers will not suffer any form of retaliation.

The reporting process is simple and secure. Users can submit reports through specific channels, providing sufficient details for an accurate assessment.

We rely on the cooperation of everyone in our business community to promote an honest, ethical and responsible work environment. The Whistleblower channel represents a vital means through which we can continue to improve and strengthen our corporate culture based on core values of integrity and respect.

The Legislative Decree 24/2023, by transposing the EU principles expressed in EU Directive 2019/1937, introduced criteria for the protection of persons who report violations of EU law and its transposition acts with the aim of enabling the emergence, contrast and prevention of unlawful conduct detrimental to organisations and the collective interest.

The regulation applies to breaches of EU regulatory provisions that harm the public interest or the integrity of the body that the reporting parties become aware of in the context of their work.

In particular, the relevant conduct can be summarised in the table below.

Breaches of European legislation

These are:

• offences committed in breach of the EU legislation set out in Annex 1 to Legislative Decree No. 24/2023 and all national provisions implementing it (even if these are not expressly listed in said Annex). It should be noted that the regulatory provisions contained in Annex 1 are to be understood as a dynamic reference as they naturally have to be adapted to changing regulations.

In particular, these offences relate to the following areas: public contracts; services, products and financial markets and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; privacy and personal data protection and network and information system security.

Examples include so-called environmental offences, such as the discharge, emission or other release of hazardous materials into the air, soil or water, or the unlawful collection, transport, recovery or disposal of hazardous waste;

• acts or omissions affecting the financial interests of the European Union (Art. 325 TFEU fight against fraud and illegal activities affecting the financial interests of the EU) as identified in EU regulations, directives, decisions, recommendations and opinions.

Think, for instance, of  fraud, corruption and any other illegal activity related to EU expenditure;

• acts or omissions relating to the internal market that jeopardise the free movement of goods, persons, services and capital (art. 26, paragraph 2, of the TFEU). This includes violations of EU competition and state aid rules, corporate tax rules and mechanisms whose purpose is to obtain a tax advantage that frustrates the object or purpose of the applicable corporate tax law;
• acts or conduct that frustrate the object or purpose of the provisions of the European Union in the areas indicated in the preceding points. This includes, for example, abusive practices as defined by the case law of the EU Court of Justice. Consider, for example, a business operating in a dominant market position. The law does not prevent such a business from gaining, on its own merits and abilities, a dominant position on a market, nor does it ensure that less efficient competitors remain on the market. However, such a business could jeopardise, by its conduct, effective and fair competition in the internal market by resorting to so-called abusive practices (adoption of so-called predatory pricing, target rebates, tying) in breach of the protection of free competition

The Reporting party may submit their report through:

• TheWhistleblowing4you IT platform (https://whistleblowing4you.assoservizibrescia.it/rbmspa/) which can be found on the company website;
• postal letter, addressed to Assoservizi srl, via Cefalonia 60, 25124, Brescia.

The report must be placed in two sealed envelopes: the first one with the identity details of the Reporting party together with a photocopy of their identification document, the second one with the report, which must necessarily contain, in addition to the necessary elements listed below, the name of the company concerned. Both envelopes must then be placed in a third sealed envelope marked on the outside for the WB reports manager;

• oral reporting, by calling the numbers 331.6669346 - 335.7138812 expressly dedicated to the Whistleblowing service, operating from Monday to Friday from 2pm-4:30pm, excluding the usual holiday periods, which are answered by the Whistleblowing Manager, or by using these numbers to request a meeting.

The report is preventively subject to a procedural check. The Reporting Manager will, in this respect, ensure that the reporting party is entitled to make the report and that the subject of the report falls within the scope of the regulation.

Subsequently, the reports are screened for admissibility , as they must allow the receiving party to carry out the appropriate investigation.

Confidentiality is guaranteed for:

• the identity of the Reporting party;
• any information related to the report.

Confidentiality is guaranteed at every stage of the handling of the report and confidential information may not be shared outside the handling of the report except with the consent of the Reporting party. 

Information on the processing of personal data

Organisational act