In accordance with the provisions of Italian Leg. Decree 24/2023, implementing EU Directive 2019/1937 on the protection of persons who report breaches of Union law, Vimar S.p.A. has updated its internal report management channel, already previously adopted, in order to ensure it complies with the above-mentioned regulation. This channel may therefore be used to report breaches of the above-mentioned regulation (set out below), respecting the confidentiality of the reporting subject, of the subject being reported and the contents of the report.
These reports, in companies that (i) employed an average of more than 50 permanent or fixed-term workers in the last year and (ii) adopted an Organisation, Management and Control Model pursuant to Italian Leg. Decree 231/01, may concern:
i. Illegal conduct relevant under Italian Leg. Decree 231/01 or breaches of the company’s Organisational model;
ii. Reports of acts or omissions contrary to Union Law or to EU deeds specified in annex A to Italian Leg. Decree 24/2023 (e.g. breaches on the subject of public tenders; services, products and financial markets and prevention of money laundering and terrorist funding; 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; protection of privacy and protection of personal data and security of network and computing systems);
iii. Acts or omissions affecting the financial interests of the Union as specified in Article 325 of the Treaty on the Functioning of the European Union specified in the relevant European Union secondary legislation;
iv. Acts or omissions concerning the internal market, as specified in Article 26, paragraph 2, of the Treaty on the Functioning of the European Union, including breaches of the European Union regulations on competition and State aid, as well as internal market breaches related to acts that breach corporate tax rules or mechanisms the purpose of which is to obtain a tax advantage that defeats the object or purpose of the applicable corporate tax law;
v. Acts or conduct which defeat the object or purpose of the provisions of Union acts in the areas referred to in the preceding points.
The internal channel for managing reports within Vimar S.p.A.
For the management of the above-mentioned reports, Vimar S.p.A. provides an IT platform that can be accessed through this section of the Company's institutional website.
On this platform, all reporting subjects (employees, self-employed workers, freelancers, consultants, collaborators, volunteers and trainees, shareholders or persons acting as administrators, directors, managers, supervisors or representatives of the company) may submit their report confidentially. The report can be made in written or oral form.
The platform is accessed by registering your data in the servers of the company managing the service and in charge of storing them with a data encryption system, which guarantees the confidentiality of the report (in any case, the registration data are not visible to Vimar and access is not registered by the latter).
The recipient of the reports is the company’s Supervisory Body, a third-party body that is impartial and adequately trained to manage reports and that will carry out the necessary investigations with the utmost confidentiality for the reporting subject, the subject being reported and the content of the report, and in compliance with the deadlines set out in Italian Leg. Decree 24/2023.
The entire report management process is also conducted in compliance with the personal data protection regulation set out in EU Reg. 679/2016.
In addition, please not that, should the requirements of Italian Leg. 24/2023 apply, a report can also be lodged through the external channel made available by ANAC (the Italian National Anti-Corruption Authority) or through public disclosure.
Finally, bear in mind that the person making a report may not be retaliated against, even indirectly, (including dismissal, suspension, lay-off, withholding of promotion, demotion, negative references, etc.) if, at the time of the report, they had reasonable grounds to believe that the information about the breaches reported, publicly disclosed or reported was true and fell within the scope of the whistleblowing legislation, and the report was made in accordance with the procedures set out in Italian Leg. Decree 24/2023.
How to access the platform
At first access, the reporting subject should register by creating their account.
Once they have logged in with their credentials, they may proceed by lodging their report by filling in all the fields and providing any documentation for its due investigation. Once completed, the report can be submitted.
In accordance with the provisions of Italian Leg. Decree 24/2023, the reporting subject will receive an acknowledgement of receipt of their report within seven days of receipt and a response to the report within three months of the acknowledgement of receipt or, failing that, of the expiry of the seven-day deadline after submitting their report.
In any case, the reporting subject may access their account at any time in order to check the status of the report sent and to communicate to the Supervisory Body any additional information or documents relevant to the assessment of the reported facts.