Whistleblowing

WHISTLEBLOWING PROCEDURE

1.  WHAT IS WHISTLEBLOWING?

Whistleblowing is the spontaneous reporting of an offense or irregularity committed in the workplace by an employee (and others), known as a “whistleblower”. The rules introduced by Legislative Decree 24/2023, implementing EU Directive No. 2019/1937 (the so-called Whistleblowing Directive), protect the confidentiality of the whistleblower and provide a number of guarantees against any retaliatory acts. Complaints, claims or requests linked to an interest of a personal nature of the Whistleblower that relate exclusively to his or her individual employment relationship or complaints relating to activities of a commercial nature do not constitute so-called whistleblowing reports.

2. HOW TO REPORT

NPE srl, aware of the importance of the integration of the reporting channels in order to protect the integrity of the Company and to guarantee the respect of the principles of legality, correctness and transparency, also towards third parties, in the exercise of the company activities, adopts the present procedure in compliance with the regulations on the subject and in particular with the Legislative Decree no. 24/2023, implementation of the EU Directive 2019/1937.In order to guarantee broad and indiscriminate access to all those who wish to make a report, the following alternative channels are made available
a)Ordinary mail to the following address: Zona Industriale 6 – 32013 Longarone (BL) to the attention of the Channel Manager; in order to guarantee confidentiality, the communication must be sent by the reporting party in a sealed envelope with an explicit indication on the envelope “Whistleblowing Report”;
b) IT Channel: beaconforce.com platform developed by the company Beaconforce S.r.l. at this address
c) Direct meeting: in the event that the whistleblower requests a meeting, it shall be arranged by the channel manager within a reasonable time and in such a way as to maintain confidentiality.

3. WHAT TO REPORT

Relevant Reports are reports concerning conduct, acts or omissions that harm the public interest or the integrity of the Company of which the reporter has become aware in the context of work and which consist of unlawful conduct relevant pursuant to Legislative Decree no. 231/2001 and violations of the 231 Model, such as, by way of example, corrupt conduct towards the Public Administration, violations of

• Occupational Health and Safety, and violations of Environmental regulations. It should be noted that such reports may only be made through internal reporting channels;
• offenses falling within the scope of European Union acts relating to the following areas: public procurement; services, products and financial markets and the prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; food and feed safety and animal health and welfare; public health; consumer protection; privacy and personal data protection and the security of networks and information systems;
• acts or omissions affecting the financial interests of the European Union;
• acts or omissions affecting the internal market, including violations of EU competition and state aid rules and corporate taxation;
• acts or conduct that frustrate the object or purpose of the provisions of the above-mentioned EU acts.

Excluded from the scope of Relevant Reports are objections, claims or requests linked to an interest of a personal nature of the whistleblower that relate exclusively to the whistleblower’s individual employment relationships or inherent to his employment relationships with hierarchically superior figures.Also excluded are information that is clearly unfounded, information that is already fully in the public domain, as well as information acquired only on the basis of indiscretions or rumors that are scarcely reliable (so-called “rumors”).

4. WHO CAN REPORT

Relevant Reports may be made by the following persons:

• employees;
• self-employed workers and collaborators carrying out their work for the Company;
• freelancers and consultants who work for the Company;
• volunteers and trainees, paid and unpaid, who work for the Company;
• shareholders and persons with functions of administration, management, control, supervision or representation, even if such functions are exercised de facto at the Company.

The data will be processed in accordance with the provisions of GDPR no. 679/2016 and Legislative Decree no. 24/2023. See Privacy Whistleblowing.