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Eurotech S.p.A. – Whistleblowing Disclosure

 

Eurotech S.p.A. (hereinafter “Eurotech”), in accordance with the requirements of Legislative Decree 24/2023 on “Implementation of EU Directive 2019/1937 of the European Parliament and of the Council of October 23, 2019, on the protection of persons who report breaches of Union law and on provisions regarding the protection of persons who report breaches of national laws,” has established an internal channel for reporting.

Such a channel can be used to signal:

  • illegal conduct relevant under Legislative Decree No. 231 of June 8, 2001 (predicate offenses by way of example: undue receipt of disbursements, fraud to the detriment of the state, a public body or the European Union for the purpose of obtaining public disbursements, fraud in public supplies), or violations of the organization and management models provided therein;
  • offenses that fall within the scope of European Union acts related to the following areas: public procurement; services, products and financial markets and prevention of money laundering and terrorist financing; product safety and compliance; transportation safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; privacy and data protection; and network and information system security;
  • The acts or omissions that harm the financial interests of the Union.

 

People who can use the channel for whistleblowing (Whistleblower or Whistleblowing Persons) are:

  • employed workers;
  • self-employed workers, partnership holders, freelancers and consultants;
  • volunteers and trainees, paid and unpaid;
  • Shareholders and persons with administrative, management, control, supervisory or representative functions (including de facto)

 

This is so even when pre-contractual situations, probationary periods, or situations after the dissolution of the legal relationship are involved if the information on violations was acquired during the course of the relationship.

All violations should be reported to the Reporting Manager through the following channel:

Online reporting portal: https://whistleblowersoftware.com/secure/eurotechspa that allows reports to be made in both written and oral form.

Eurotech has assigned the role of Reporting Manager to a committee consisting of two internal individuals (Compliance Manager and Human Resources Manager) and an external individual (member of the Supervisory Board), providing for the external individual to sign a special contract.

All communication between the Reporting Manager and the reporter should be through the Online Reporting Portal using the codes that will be provided to the reporter when the report is opened.

Eurotech is committed to protecting the confidentiality of the whistleblower, any facilitators of whistleblowers, and the persons reported.

Furthermore, Eurotech does not allow or tolerate any form of retaliation or discriminatory measures towards the reporter related, directly or indirectly, to the report.

The report should be as circumstantial as possible in order to allow for fact-finding by the Reporting Manager.

In particular, it is necessary that they result:

  • The time and place at which the reported event occurred;
  • The clear description of the fact;
  • the generalities or other elements that would make it possible to identify the person(s) to whom the reported facts can be attributed.

 

The Reporting Manager shall issue the reporter with an acknowledgement of receipt of the report within seven days from the date of receipt and provide the reporter with feedback on the outcome of the report within three months from the date of the acknowledgement.

Anonymous reports will still be acquired if they contain substantiated facts. It will not be possible in the case of an anonymous report, to guarantee protection from retaliation related to the report as well as the right to obtain the acknowledgement of receipt and subsequent acknowledgement mentioned above.

Legislative Decree 24/2023 also provides for the establishment of an external reporting channel is activated at the National Anticorruption Authority (ANAC).

This channel can be used only for reports concerning violations of specific EU regulations stipulated in Legislative Decree 24/2023.

The reporter may use the external reporting channel only under the following conditions:

  • the internal channel despite being mandatory, has not been activated by the Company or, even if activated, does not comply with the provisions of the decree with reference to the subjects and methods of submission of internal reports, which must be able to guarantee the confidentiality of the identity of the reporter and other protected subjects;
  • the reporting person has already made an internal report and it has not been followed up by the Reporting Manager: the report has not been dealt with within a reasonable time, or action has not been taken to address the violation;
  • the reporting person has reasonable grounds for believing on the basis of factual circumstances and information actually obtainable and, therefore, not on mere inferences, that if he or she made an internal report it would not be effectively followed up ( e.g., the ultimate manager in the work context is involved in the violation there is a risk that the violation or related evidence might be concealed or destroyed, the effectiveness of investigations carried out by the competent authorities might otherwise be compromised) or that the report might result in the risk of retaliation (e.g., also as a consequence of violating the obligation to keep the reporter’s identity confidential);
  • the reporting person has reasonable grounds to believe that the violation may pose an imminent or obvious danger to the public interest (for example, where the violation requires urgent action, to safeguard the health and safety of persons or to protect the environment).

 

ANAC has set up the following alternative reporting channels:

  • computing platform
  • oral reports
  • Direct meetings set within a reasonable time.

 

For operating procedures on making an external report on the external channel, please refer to the ANAC website: https://whistleblowing.anticorruzione.it.

Reports whose contents differ from those stipulated in the regulations do not fall within the scope of Legislative Decree 24/2023 and therefore do not guarantee the protection of the reporter.

However, Eurotech will consider and implement all necessary actions to protect the reporter even where the same concerns other reports, such as but not limited to:

  • Discriminatory acts: conduct that directly or indirectly makes a distinction, exclusion, restriction or preference because of religion, belief, disability, age or sexual orientation;
  • Harassment: unwanted behavior with sexual connotations or any other type of discrimination based on sex that offends the dignity of men and women in the work environment, including physical, verbal or nonverbal attitudes;
  • bullying: aggressive and persecutory behavior put in place in the workplace in order to target and marginalize the person who is the victim;
  • Misconduct in the workplace.

 

For further details please refer to the respective links below.

 

1 The national legislation includes: illicit conduct relevant under Legislative Decree No. 231 of June 8, 2001(predicate offenses by way of example: Undue receipt of disbursements, fraud to the detriment of the State, a public entity or the European Union for the purpose of obtaining public funds, computer fraud to the detriment of the State or a public entity and fraud in public supplies), or violations of the organization and management models provided therein. National legislation includes: illegal conduct relevant under Legislative Decree No. 231 of June 8, 2001(predicate offenses by way of example: Undue receipt of disbursements, fraud to the detriment of the State, a public body or the European Union for the purpose of obtaining public disbursements, computer fraud to the detriment of the State or a public body and fraud in public supplies), or violations of the organization and management models provided therein.

European Union regulations include:

  • offenses within the scope of the acts of the European Union related to the following areas: public procurement; services, products and financial markets and prevention of money laundering and terrorist financing; product safety and compliance; transportation safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; privacy and data protection; and network and information system security;
  • The acts or omissions that harm the financial interests of the Union.