As of 15 July 2023, the whistleblowing legislation introduced by Legislative Decree No. 24/2023, implementing EU Directive 2019/1937, has entered into force. The new regulation strengthens the protection of individuals who report unlawful conduct by expanding both the scope of protected persons and the procedures designed to safeguard whistleblowers against any form of retaliation.
The following may be reported:
- Corruption or attempted corruption;
- Fraud, embezzlement and other unlawful conduct;
- Violations of the Code of Ethics;
- Violations of the Organisation, Management and Control Model pursuant to Legislative Decree 231/2001 (Model 231);
- Conflicts of interest;
- Unfair commercial practices;
- Accounting or administrative irregularities;
- Violations of health and safety regulations;
- Environmental violations;
- Violations of data protection and cybersecurity regulations.
The following do not fall within the scope of whistleblowing:
- Personal complaints;
- Requests relating to the employment relationship;
- Issues concerning salary, leave, job classification or personnel management that are not connected with a breach of law.
The Company provides two internal reporting channels for submitting reports: written and oral.
In accordance with the guidelines issued by ANAC (Italian National Anti-Corruption Authority) and Confindustria, written reports must be sent by registered mail to:
IDC – Indicom Document Care S.p.A.
Via Antonio Carnevali 39
20158 Milan – Italy
To ensure the confidentiality of the whistleblower’s identity, two separate envelopes must be used: the first containing the whistleblower’s identification details together with a copy of a valid identity document, and the second containing the report itself.
Both envelopes must then be placed inside a third envelope marked “Confidential – Whistleblowing Officer – Compliance Office” or, if the report concerns the Compliance Office itself, “Confidential – Whistleblowing Officer – Sole Director”.
For oral reports, two dedicated telephone numbers are available and are indicated in the Company’s internal Whistleblowing Procedure.
The content of oral reports is either documented in written minutes, which must be signed by the whistleblower, or recorded with the whistleblower’s prior consent. Any reports received by persons other than the designated Whistleblowing Officer will be forwarded to the competent recipient within seven days.
Whistleblowers are encouraged to use only the reporting channels described above and to provide all relevant information and supporting documentation necessary to enable an effective assessment of the reported facts.
