Our Reporting System for violations and irregularities
We embrace an open corporate culture based on ethics, transparency and responsibility, and inspired by the values that guide us: trust, integrity, courage, passion and inclusion.
A system for receiving and managing Reports(Whistleblowing) is currently in place, which can be activated by both employees and external parties, relating to any non-compliance with the law, internal rules, the Code of Ethics and the Social Responsibility Policy, as well as issues relating to the Internal Control System, Corporate Disclosure, the Administrative Liability of companies (Legislative Decree No. 231/2001), fraud and conflicts of interest.
This System ensures the highest level of confidentiality and privacy in the handling of communications received, protecting the whistleblower, the reported party and the persons involved.
Who can submit Reports?
By way of example and without limitation, Reports may be submitted by: employees, co-workers, professionals, consultants, interns, suppliers, shareholders or anyone with administrative or control functions within group companies, such as Directors or members of the Supervisory Board.
What can be reported?
Reports, which must be as detailed as possible, must concern violations that fall within the scope of application referred to in Article 2 of Legislative Decree 24/2023. The legislation defines "violations" as any conduct, act or omission that is likely to harm the public interest or the integrity of the Company, which whistleblowers have become aware of in the context of their work relating to the companies of the Sesa Group. Reports that do not fall within the scope of application of the legislation will not be taken into consideration.
How to report?
Reports can be sent: (i) via the IT platform accessible from the Sesa website and the company intranet: https://whistleblowing.sesa.it/Whistleblowing?code=SESA; (ii) by email to the bodies responsible for handling the report ([email protected]); (iii) verbally, by means of a statement made by the reporting person at a special hearing.
Report management
The management of the reporting channel and the verification of the validity of the circumstances described in the report are carryed out by the Supervisory Body and the Group Compliance Officer, who verify the facts reported in accordance with the principles of objectivity and confidentiality, including, where necessary, hearing the reporter and any other persons who may be able to provide information on the facts reported.
External reporting channel and public disclosure
Legislative Decree No. 24/2023 provides for the possibility of making external reports to the National Anti-Corruption Authority (ANAC) and public disclosures of violations in the cases expressly provided for by the law. External reports to ANAC are only permitted in the following cases: where there is no internal reporting channel or where the internal reporting channel does not comply with the requirements of the law; where the whistleblower has already made an internal report that has not been followed up; in cases where the whistleblower has reasonable grounds to believe that, if they were to make an internal report, it would not be effectively followed up or that it could lead to the risk of retaliation; in cases where the whistleblower has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest.
External reporting channel managed by ANAC: https://www.anticorruzione.it/-/whistleblowing
Guarantee of confidentiality and protection
The whistleblower and any persons involved in the report are guaranteed absolute confidentiality.
In the case of anonymous reports, it is not possible to trace the identity of the whistleblower. No form of personal or professional retaliation is permitted or tolerated on the basis of the report made. All processing of personal data is carried out in compliance with personal data protection legislation.
