WHISTLEBLOWING

SICIM has put in place a solid and effective system to discourage, detect, investigate and report wrongdoing in society and the reporting process is a substantial part of this system. SICIM is equipped with a reporting management platform, including anonymous ones, which ensures the reception, management, analysis and processing of reports, including anonymous ones, received by SICIM in Italy and abroad.

In compliance with the provisions of Directive (EU) 2019/1937 and the related transposition laws, the organisation, management and control model pursuant to Legislative Decree no. 231 of 2001 and the internal Anti-Corruption Regulatory Instruments, we have adopted a reporting management system that allows us to manage reports, even anonymous, received by SICIM.

Whatever channel is used, we guarantee the receipt, analysis and processing of reports submitted by anyone, even anonymously:

• SICIM people (Resources who, regardless of the type of contract, carry out their activities within the company, even without the payment of a salary for the sole purpose of learning, employees of third-party companies who have direct relationships with the company);
• Other third parties in relationships of interest with SICIM, e.g. Business Partners, customers, suppliers, SICIM auditing firms, consultants, collaborators;
• All stakeholders, including shareholders and persons with administrative, management, control, supervisory or representative functions.

These are reports concerning behavior in violation of the Code of Ethics, laws, regulations, internal regulations, provisions of the Authorities, Model 231.
Maximum confidentiality is guaranteed on the subjects and facts reported, as well as on the identity of the whistleblowers, so that whoever makes the report is not subject to any form of retaliation.

Without prejudice to the preferential use of the reporting channels made available by SICIM, in the cases strictly indicated pursuant to art. 6 of Legislative Decree 24 of 10 March 2023, it is also possible to report to the competent authority in the matter (ANAC).

The information and personal data that are communicated in the context of reports are processed to manage and follow up on the reports themselves, as well as investigate any reported conduct and take the necessary measures in compliance with applicable laws, including data protection legislation personal. For further information on the methods and purposes of the processing of personal data included in the reports and collected during the procedure, we invite you to consult the information for the processing of data available on this page.