“Whistleblowing” is raising concerns by people of Gruppo Mittel (people who, regardless of the type of their employment contract, carry out activities within Gruppo Mittel) or by people connected to Gruppo Mittel (for example, customers, suppliers, consultants, stakeholders including shareholders and people in charge of administration, management, control, supervision or representation functions), who during their duty come across wrongdoings that may damage the company or may harm the public interest.
For example, such concerns may refer to violations of Code of Conduct; of the Organizational Model 231; accounting, administrative or tax compliance irregularities, also in drafting annual financial statements; false declarations and certifications; violations of environmental, health & work safety and control regulations; the promise of/giving of money, goods and services or other benefits aimed at corrupting suppliers, customers or public officials; actions likely to create damage to the image of the companies belonging to Gruppo Mittel; violation of human rights, privacy, harassment and discrimination; other offenses that fall within the scope of application of the EU legal acts.
Gruppo Mittel encourages whistleblowing reports that are done in good faith and forbids those that have purely defamatory or slanderous purposes, as well as reports that relate exclusively to the aspects of private life, without any direct or indirect connection with the company business.
Whoever will report wrongful intent or gross negligence, which will prove unfounded afterwards, may be subject to disciplinary sanctions. This measure aims at ensuring the responsible use of the tool and reducing unwarranted reporting.
Reports can be submitted through a web-based IT platform adopted by Gruppo Mittel and named “Globaleaks”, which is directly accessible through this link: https://glks.mitteladg.it or by using the below button “Submit a report“.
The platform ensures the confidentiality of the reporter’s identity, that of the reported person and/or any of the third parties/witnesses cited, as well as the facts stated in the report.
The function in charge of receiving Reports coincides with the Head of the Internal Audit function of the parent company Mittel S.p.A.
Gruppo Mittel offers also the possibility to submit reports anonymously as long as adequately substantiated and in line with the adopted Whistleblowing procedure.
Once the reporting procedure is finished, a 16-digit numeric “report code” is generated, which must be retained and used to verify the report’s status in order to monitor it’s progress or, if necessary, to modify/upload any supporting documentation.
In addition to the aforementioned Platform (recommended internal reporting channel), which is preferable due to better guarantees provided, a report can also be submitted:
· by ordinary mail – addressed to the attention of the Head of Internal Audit of Mittel S.p.A. – Via Borromei 5, 20123 Milan – following the instructions provided by the Whistleblowing procedure;
– orally:
– through a specific “send a voice report” function present on the platform;
– through a personal meeting with the Head of Internal Audit of the parent company Mittel S.p.A., to be requested through the platform (please, specify “request for a direct meeting” in the notes).
For other general information on Whistleblowing you can freely browse by clicking on the sections below.
