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Whistleblowing

Falc S.p.a. attaches great importance to observing the ethical principles it has adopted, as well as compliance with the rules and regulations in force in the country in which it operates.

In compliance with the provisions of Legislative Decree No. 24/2023, which transposed Directive (EU) 2019/1937 on “Whistleblowing”, we have set up dedicated channels for internal whistleblowing. In particular, we have a dedicated platform that ensures protection and confidentiality for both the whistleblower and the persons involved, as well as the confidentiality of the content of the reports. There remains, however, the possibility of organising in-person meetings.

The aforementioned reporting channels allow interested parties to report, even anonymously, violations of national or European Union regulations that harm the public interest or the integrity of the Company. In addition, it is possible to report unlawful conduct relevant pursuant to Legislative Decree 231/2001 or violations of the Organisation, Management and Control Model, of which one has become aware within one’s own work context.

For any clarifications or suggestions, please contact the dedicated channels available to FALC S.p.a. at: https://falc.whistlelink.com

In addition to internal reporting channels, if certain conditions are met, the person submitting the report may proceed with an external report, as provided for in Articles 6 et seq. of Legislative Decree No. 24/2023.

FAQ

How can my report help?

Your report is crucial for investigating unlawful and unethical situations, identifying risks at an early stage and preventing potential damage to the company’s reputation. In this way, you will help minimise risks for the company and all its employees.

The reporting system is available to whistleblowers who have sufficient reason to believe that the report is true, based on the factual circumstances and information available to them. In order to conduct an accurate investigation of report, we need specific information on specific facts.

Who can submit a report?

The whistleblowing legislation and related protections apply to the following categories of persons who report violations occurring in the context of their work environment:
  •  employed workers (e.g. part-time, intermittent, fixed-term, agency, apprenticeship, ancillary work or workers performing casual work);
  • self-employed persons working at the companies;
  • freelancers and consultants working for the companies;
  • trainees and interns;
  • shareholders;
  • persons with administrative, management, control, supervisory or representative functions at the companies.

The protection of reporting persons also applies in the following cases:
  • before the start of the legal relationship, if you have acquired information on infringements during the selection process or in other pre-contractual stages;
  • during the probationary period;
  • after the conclusion of the legal relationship, if you have acquired information on violations in the course of the relationship.

What kind of behaviour should I report?

Contact the Whistleblowing Committee if, in your work context, you become aware of conduct or events that may constitute violations of national or European Union regulations that harm the public interest or the integrity of the Company.

 

Whistleblowing legislation, with its attendant protections, does not apply to complaints, claims or demands related to a personal interest of the whistleblower that relate exclusively to their individual employment relationships.

 

Reported violations may concern:

  • violations of the Organisation, Management and Control Model adopted by the Company pursuant to Legislative Decree 231/2001;
  • offences related to the following areas: public procurement; financial services, products and 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;
  • violations affecting the financial interests of the European Union;
  • competition and internal market violations.

How can I submit an internal report?

You can submit a report via the secure server of a specialised company independent of the Company, which can be reached via the link indicated in this section of the website.


Alternatively, it is possible to request a direct meeting at the Company’s internal office, specifically identified and authorised to manage internal reporting channels, known as the “Whistleblowing Committee”, composed of the Director of Auditing and the Director of Legal Affairs and Privacy/Antitrust Compliance.

What happens after having submitted a report?

All reports are received and handled by the Whistleblowing Committee (see above).
 

After submitting a report, the whistleblower:

  • receives an acknowledgement of receipt of the report within seven days of its receipt;
  • may be contacted further to provide the Whistleblowing Committee with information, additions or clarifications;
  • receives an acknowledgement of the report within three months of the date of the acknowledgement of receipt or, in the absence of such an acknowledgement, within three months of the expiry of the seven-day period from the submission of the report.

Is it possible to submit a report anonymously?

Yes, it is possible to report anonymously. However, the whistleblower is invited to identify themselves to create the best possible conditions for an effective investigation.

Are there any forms of protection for the whistleblower?

The whistleblower enjoys the broadest protection of their confidentiality, which is also extended to other persons provided for by the applicable legislation, such as facilitators (natural persons who assist the whistleblower in making the report and who work in the same work context), the whistleblower’s colleagues and those who work in the same work context, as well as the whistleblower’s own entities. Moreover, the whistleblower may not suffer any form of retaliation from having submitted the report. Should this occur, without prejudice to the intervention and sanctioning powers of ANAC, the Company itself is required to remedy the situation with appropriate initiatives, aimed at:
  • on the one hand, protecting the whistleblower and stopping the harassing conduct to which they have been subjected or to render ineffective any measures taken against them. Possible actions include demotion, change of duties, failure to convert the contract from fixed-term to open-ended (by way of example but not limited to);
  • on the other hand, imposing sanctions under the corporate disciplinary system on those who have engaged in such conduct.
The same protections are guaranteed in the case of external channels, disclosure and reporting. However, in all circumstances, no protection is provided for those who make an unfounded report with malicious intent or gross negligence, with a finding to that effect by the judicial authorities.