Whistleblowing

Reporting violations, wrongdoings and irregularities

The Company promotes a corporate culture based on legality, fairness, transparency, and responsibility.

In this context, a whistleblowing system has been adopted that allows you to report, in a confidential and protected manner, behaviors, acts, or omissions that may constitute violations of the law, European Union law, the Organization, Management, and Control Model adopted pursuant to Legislative Decree no. 231 of June 8, 2001, the Code of Ethics, or internal company procedures.

The applicable legislation is contained in Directive (EU) 2019/1937 and Legislative Decree no. 24 of 10 March 2023, which protect individuals who report violations of Union law and national regulations.

Who can make a report

The following may report matters within the limits established by current legislation and company procedures:

  • employees;
  • managers;
  • collaborators;
  • consultants;
  • self-employed;
  • trainees and interns;
  • suppliers, contractors and subcontractors;
  • third parties who have professional, commercial or contractual relationships with the Company.

What can be reported

The following may be reported, by way of example:

  • violations of national or European Union legal provisions;
  • administrative, accounting, civil or criminal offenses;
  • conduct relevant pursuant to Legislative Decree 231/2001;
  • violations of Model 231, the Code of Ethics and internal procedures;
  • behaviors contrary to the principles of integrity, fairness and transparency;
  • acts or omissions intended to conceal irregularities or violations.

How to make a report

The report can be sent through the internal reporting channel set up by the Company.

Secure reporting channel

Access the dedicated portal via the following link: https://bonoeditta.segnalazioni.eu

The portal allows you to submit a written report, even anonymously, and to communicate confidentially with the Channel Manager, maintaining an identification code to track the status of your report.

Oral canal

If required by company procedure, it is also possible to request:

  • a dedicated telephone interview;
  • a direct meeting with the Channel Manager.

To request a meeting or receive operational instructions: whistleblowing@bonoeditta.it

Useful information for reporting

To facilitate the management of the report, it is advisable to indicate:

  • a clear and complete description of the facts;
  • reference date or period;
  • area, function or process affected;
  • any subjects involved;

documents or other elements useful for the verification.

Protection of the whistleblower and confidentiality

The Company guarantees:

  • the confidentiality of the whistleblower's identity;
  • the confidentiality of the identity of the persons involved or mentioned in the report;
  • the protection of the content of the report and related documentation;
  • the prohibition of retaliation, discrimination or penalization against anyone who makes a report in good faith.

Personal data protection

The processing of personal data related to the management of reports is carried out in compliance with:
  • of Regulation (EU) 2016/679 – GDPR;
  • of Legislative Decree 30 June 2003, n. 196;
  • of Legislative Decree 10 August 2018, n. 101;
  • of the applicable legislation and the current company procedure.
Privacy information dedicated to Whistleblowing: Privacy Policy

Report Management

Reports are received and processed by the Whistleblowing Channel Manager, identified by the Company in accordance with current internal regulations.

The Company ensures that reports are managed in accordance with:

  • impartiality;
  • timeliness;
  • process traceability;
  • compliance with current legislation;
  • coordination with the internal control system.

Contacts

For further information on how the reporting system works, please use the following contact details:

Whistleblowing Channel Manager
Dr. Antonino Casano
nino@studiocasano.it

Supervisory Body (ODV)
odv@bonoeditta.it

Reporting channel
https://bonoeditta.segnalazioni.eu

Privacy disclaimer
Privacy Policy

Competent authority for the external channel

In the cases provided for by current legislation, it is also possible to appeal to the external channel established by the National Anti-Corruption Authority (ANAC).

For more information: https://www.anticorruzione.it/-/whistleblowing