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THE WHISTLEBLOWING PORTAL
Il Sole 24 ORE S.p.A. (the “Company”) makes the Whistleblowing Portal (the “Portal") available to all those who wish to report, in good faith, behaviour or events that may constitute violations of (national or EU) laws or regulations or of company procedures, or that are not in any case compatible with ethical behaviour. Reports must be made to protect the public interest and the integrity of companies.
The Portal allows the whistleblower to choose whether or not to provide his identity. Access to the Portal is managed in “no-log” mode in order to prevent the identification of the whistleblower who wishes to remain anonymous. In any case, the whistleblower may supplement their personal details at a later stage through the Portal.
After access, the whistleblower will be guided in filling in a questionnaire that will allow them to provide, in written or verbally, full information for the report (events, context, etc.). The whistleblower is also given the option, again through the Portal, to request a meeting in person.
When sending the report, the Portal will issue the whistleblower with a unique identification code (ticket). This number, known only to the whistleblower, cannot be recovered in any way if lost. The ticket will be used by the whistleblower to access the report through the Portal to: monitor its progress; enter further elements to substantiate the report; supplement his personal details; submit or answer any follow-up questions. Indeed, the Portal allows a virtual conversation to take place between the whistleblower and the recipient, guaranteeing the necessary confidentiality and, at the Whistleblower's discretion, anonymity.
WHO HANDLES THE REPORT
The task of receiving reports is entrusted to the Company's Internal Audit Department.
The handling of reports for the Company is carried out by the Ethics Committee, acting as a board, comprising:
- the Central HR and Organisation Manager;
- the Head of Legal and Corporate Affairs;
- the Head of Internal Audit.
If, in the course of the checks and investigations, elements of interest should arise, within the meaning of Italian Legislative Decree no. 231/01, the matter is handled jointly with the Company’s Supervisory Body.
The Ethics Committee has its own Operating Rules, which describe how the Internal Audit Department is to inform it of reports and govern how to handle reports involving one of the members of the Committee itself (i.e. where there is a “conflict of interests”).
An acknowledgement of receipt will be sent to the whistleblower within 7 days from the date of submission via the Portal. This will be followed by further information, again through the Portal, upon completion of the investigation into the reported event, but no later than 3 months.
PROTECTION AND RESPONSIBILITY OF THE WHISTLEBLOWER
No direct or indirect retaliation or discrimination may be implemented against a person who has made a report in good faith. In addition, sanctions are provided for those who violate the whistleblower protection measures.
Sanctions shall be imposed on the whistleblower, where possible, in the event of reports made with malice or gross negligence or which prove to be false, unfounded, defamatory or in any case made with the sole purpose of harming the Company, the person reported or persons concerned by the report shall be sanctioned. The Company may also take appropriate legal action.
PROTECTION OF THE REPORTED PERSON
A report alone shall not suffice to initiate any disciplinary proceedings against the reported person. If, following concrete findings concerning the report, the decision is made to proceed with the investigation, the reported person may be contacted and will be entitled to provide any necessary clarification.
The Portal is intended for use by those who, in good faith and in accordance with ethical principles of integrity, wish to report conduct that potentially does not comply with laws and regulations or with the principles and internal procedures of the 24 ORE Group, of which they have become aware. Such reports are also accepted anonymously. The Company will prosecute anyone making a report in bad faith, with defamatory intent or not in the correct spirit of cooperation with the company.
The protections afforded to the Whistleblower do not apply to challenges, claims or demands linked to a personal interest of the Whistleblower that relates exclusively to their individual employment relations, or is inherent to their employment relations with hierarchically superior figures. You are therefore asked NOT to use the Portal with reference to such matters; in general, the 24 ORE GROUP urges its employees to resolve any employment disputes, where possible, through formal or informal dialogue with their colleagues and/or their direct supervisor.
Similarly, please do not use the Portal for complaints, requests for assistance and other commercial matters: for such purposes the appropriate sections on the websites of the 24 ORE Group companies or customer services (02 30300600) are available.
Reports must be made in a spirit of responsibility, be of interest to the common good and fall within the types of non-compliance for which the system has been implemented.
Please refrain from making any reports that do not fall under the above-mentioned cases.