Whistleblowing Reports

Giflor Srl understands the importance of establishing effective reporting channels in order to safeguard the integrity of the company, while guaranteeing compliance with the fundamental principles of legality, fairness and transparency. This commitment also extends to relationships with third parties during the execution of company activities.

Transparency and clarity in the handling of whistleblowing reports are crucial to fostering an ethical and responsible business environment. Giflor is committed to ensuring confidentiality and non-retaliation for those who report in good faith.

What behaviors can be reported?

“Relevant Reports” are considered all reports that concern conducts, acts or omissions that harm the public interest or compromise the integrity of the Company relating to situations in the work environment and may include:

• unlawful conducts according to Legislative Decree No. 231/2001 and violations of the 231 Model, such as: corruptive behaviors towards the Public Administration, violations of Occupational Health and Safety, violations of Environmental regulations. Such reports may be made exclusively through internal reporting channels;
• unlawful acts that fall within the scope of the acts of the European Union related to the following areas: public procurement; financial services, financial products and market, prevention of money laundering and terrorist financing; product safety and compliance; transportation safety; environmental protection; public health; consumer protection; privacy and personal data protection; and network and information system security;
• acts or omissions that damage the financial interests of the European Union, such as fraud, corruption and any other illegal activities related to Union expenses;
• acts or omissions concerning the internal market, including violations of EU rules on competition and State aid, as well as on corporate taxes, free movement of goods, persons, services and capital;
• acts or conducts that undermine the object or purpose of the provisions set forth in the acts of the European Union in the above-mentioned areas. For example, so-called abusive practices that are in violation of the protection of free competition (adoption of predatory pricing, target discounts, tying sales, etc.).

The following reports are not considered Whistleblowing reports: reports related to a whistleblower’s personal interest that pertain exclusively to his or her individual work relationships; unsubstantiated news and information that is already totally in the public domain, information acquired only on the basis of rumors (so-called rumors) or that is alleged, defamatory or intended to harm the reported person or entity.

Who can make a report?

People who work within the company as:

• employees;
• self-employed workers and collaborators who perform their work activities at the Company;
• freelancers and consultants who perform their work at the Company;
• volunteers and trainees, paid and unpaid, who perform their activities at the Company;
• individuals with functions of administration, management, control, supervision or representation at the Company,     b, if the information on violations was acquired during the selection process or at other pre-contractual stages such as during the probationary period or after the dissolution of the legal relationship if the information on violations was acquired during the course of the relationship.

How to make an internal report?

Internal collaborators, members of corporate bodies or external individuals (such as consultants, freelancers, trainees, etc.) can submit reports confidentially or anonymously through two main channels (written and oral):

1. Online Platform for Reporting – Whistleblowing https://giflor.signalethic.it
2. Telephone lines operating Monday through Friday and from 09:00 to 18:00, at 328 7514819 – 327 3240442 with referral to the Channel Managers. In order to ensure confidentiality, the whistleblower must immediately communicate that he/she intends to make a “Whistleblowing Report.”

A direct meeting with the Channel Manager can also be arranged upon request of the reporter. The face-to-face meetings shall be conducted only by the Channel Manager in a confidential manner and through the drafting of the report card.

In accordance with the Whistleblowing Decree, the above reporting channels guarantee the utmost confidentiality regarding the identity of the reporter, the person involved and anyone mentioned in the report, as well as the content of the report and related documentation.

The management of the reporting channel is entrusted to Mr. Borsato Marco and Mr. Dalla Fontana Denis (the “Channel Managers“).

Upon certain conditions expressly provided for in Legislative Decree No. 24 of March 10, 2023, the reporting person may make an external report to ANAC (National Anticorruption Authority) with the same procedures and guarantees for internal reporting: www.anticorruzione.it/whistleblowing

How are reports handled?

The Channel Manager, upon reception of the report, carries out the following activities:

• sends acknowledgement of receiving the report to the reporter within seven days from the date of receipt;
• maintains contacts with the reporter and may request additional information;
• follows up on the reports received by activating the individuals assigned to handle the report;
• provides feedback to the reporter within three months from the date of the acknowledgment of receipt or, in the absence of such an acknowledgment, within three months from the expiration of the seven-day period from the submission of the report.

For the appropriate processing of the report, internal or external parties may be involved, in view of the specific technical and professional skills required, who do not have a conflict of interest and who will in any case be bound by the obligations of confidentiality provided for in the regulations.

Following the outcome of the investigation, if the report turns out to be well-founded, the Manager of the reporting channel will refer to the competent internal bodies/functions for the relevant follow-ups for the purpose of activating preventive, corrective or disciplinary actions against the reported person.

The managers of the reporting channel are:
Borsato Marco 328 7514819
Dalla Fontana Denis 327 3240442

The whistleblowing reports policy can be accessed in full at the link below, and is intended to provide the necessary information regarding available channels, procedures to be followed, and preconditions for making reports, both internal and external.

Data will be processed in accordance with the provisions of GDPR No. 679/2016 and Legislative Decree No. 24/2023. For more information please see the Privacy Whistleblowing document.