Our commitment to whistleblowing
The Company promotes an open corporate culture that is based on ethical principles, of transparency and responsibility, inspired by our guiding values. For this reason Solesi S.p.A. offers internal channels to report to the Whistleblowing Reports Manager information relating to any violations of laws, regulations, the Code of Ethics and Conduct, as well as the 231 Organizational Model.
Through the active and responsible participation of both employees and third parties, reporting non-compliant behavior allows the company to identify potential irregularities and promptly adopt the necessary corrective actions, thus preventing possible economic or reputational damage.
Whistleblowing Procedure
The Whistleblowing procedure regulates the management of reports adopted by Solesi S.p.A., in accordance with the provisions of the Legislative Decree n. 24 issued on 10 March 2023 (“Whistleblowing Decree”), defining its functioning, the identification of the type of relevant reports and the subjects who can carry them out, the competence and methods of managing the analysis and investigation activities resulting from the receipt of the reports and the related terms, the measures of protection of the whistleblower, the conditions for carrying out external reports and/or public disclosure as well as the methods and terms of data retention for the purposes of management activities in the Whistleblowing field, also in compliance with privacy legislation. For further information, download and consult the whistleblowing guidelines, found at the end of this page.
Who can report?
Anyone can send a report, even anonymously: employees, former employees, candidates for job positions, partners, customers, suppliers, consultants, collaborators, partners and, more generally, anyone with a legitimate interest in the activity company of Solesi S.p.A..
The report must contain sufficient details to allow the facts reported to be ascertained (e.g. elements that allow the identification of the subjects involved, the context, place and time period of the facts reported with any accompanying documentation).
What can be reported?
Offenses, irregularities or in any case conduct carried out in violation may be reported:
• national provisions relating to the crimes mentioned in the Legislative Decree. 231/2001;
• national and European provisions regarding some specific sectors (for the list consult the Whistleblowing Procedure);
• of the financial interests of the Union, of the internal market and of provisions referred to in Union acts;
• the Corporate Organization and Management Model pursuant to Legislative Decree. 231/2001;
• the company’s Anti-Corruption Management System;
• the corporate Code of Ethics and Conduct;
• conduct that may cause damage or prejudice, even if only to its image or reputation, to Solesi S.p.A..
What cannot be reported?
Reports that do not fall within the scope of application of the whistleblowing procedure cannot be made.
More precisely, reports cannot be made that:
• go beyond the purposes described previously;
• are unfounded due to lack of objective evidence;
• are related to disputes, claims or requests linked to a personal interest or inherent to your working relationship with your hierarchical superior;
• they are already regulated, as a typology, on a mandatory basis by other European Union or national acts;
• report “rumors”, without reliable references or based on mere suspicions or unprovable hypotheses.
How to report?
Solesi S.p.A. provides the following channels for submitting reports:
⇒ Whistleblowing Portal, suitable for guaranteeing the confidentiality of the identity of the whistleblower through the use of secure protocols and encryption tools;
⇒ ordinay mail, addressed to the Whistleblowing Reports Manager, to the attention of the Supervisory Body of Solesi S.p.A., at the headquarters in via Stentinello, 9 C. da Targia – 96100 Siracusa, using the following wording “whistleblowing report, confidential – do not open ”;
⇒ verbally during a meeting with the Whistleblowing Reports Manager.
How are reports handled?
Anyone who receives a report, in any form (written or oral), must transmit it promptly, and in any case within 7 days of receipt, via the aforementioned channels, to the Wistleblowing Reports Manager, giving simultaneous notice of the transmission to the reporter (if known) and guaranteeing absolute confidentiality.
Specifically, all reports sent via the channels described are addressed, received and examined by the Supervisory Body of Solesi S.p.A., which operates as Whistleblowing Reports Manager pursuant to Legislative Decree 24/2023. Within 7 days of receipt, an acknowledgment of receipt of the report will be given and within 3 months of this notice, feedback will be provided on the follow-up that is given or intended to be given to the report.
Guarantee of confidentiality and protections
Legislative Decree March 10, 2023, No. 24 (transposition of European Directive 2019/1937 on Whistleblowing) has introduced a unitary regulation for reporting channels and protections guaranteed to whistleblowers in both the public and private sectors.
Absolute confidentiality is guaranteed to the whistleblower, facilitator, and individuals involved in the reporting process. In the case of anonymous reports, it is not possible to trace the identity of the whistleblower.
Any form of personal or professional retaliation for reporting is neither permitted nor tolerated. If you believe you have experienced retaliation due to your report, you can report it to the National Anti-Corruption Authority (ANAC) through the IT platform.
All processing of personal data is carried out in compliance with data protection regulations.
Reports to the National Anti-Corruption Authority (ANAC) through an external channel
In the event that, after making a report through internal channels, one does not receive the acknowledgment of receipt and/or feedback on the action taken regarding the report, or if there are reasonable grounds to believe (based on concrete circumstances and information that can be obtained) that the internal report will not be effectively followed up or that it could result in retaliation, or that the violation may pose an imminent or clear danger to public interest, it is possible to submit a report to ANAC through the IT platform. ANAC’s website provides a list of Third Sector Entities that offer support to whistleblowers (information, assistance, and free consultations on reporting procedures and protection from retaliation).
