Whistleblowing
How to make a report
The report may be made using the web channel, through the MYGOVERNANCE site suitable to ensure by computer modalities the maximum confidentiality of the identity of the reporter in compliance with the relevant provisions of Legislative Decree 24/2023.
They will be able to proceed with reporting:
- all employees of Demenego and its wholly owned subsidiaries, regardless of their contractual status;
- the self-employed, employees, freelancers, consultants, volunteers and trainees of Demenego and its wholly owned subsidiaries;
- shareholders and persons who hold within Demenego and its wholly owned subsidiaries functions of administration, management, control supervision or representation.
The Report must be circumstantiated i.e., made with a sufficient degree of detail to enable the facts reported to be ascertained and must relate to:
- unlawful conduct relevant under Legislative Decree 231/2001 and violations of the Organization, Management and Control Models adopted by Demenego and its wholly owned subsidiaries;
- offenses that fall within the scope of the European Union or national acts listed in the Annex to Legislative Decree 24/2023 or domestic legislation that constitutes their implementation of the acts of European law listed in the Annex to Directive (EU) 2019/1937;
- acts or omissions detrimental to the financial interests of the European Union protected under Article 325 of the Treaty on the Functioning of the European Union;
- acts or omissions concerning the internal market referred to in Article 26.2 of the Treaty on the Functioning of the European Union, including violations of competition and state aid rules and corporate taxes;
- any conduct likely to frustrate the object or purpose of the provisions set forth in the Union Acts in the areas identified in (b), (c) and (d);
- Any other possible administrative, accounting, civil, and criminal offenses of any nature other than the above.
Reports in application of Article 1 paragraph 2 of Legislative Decree 24/2023 may not concern:
- disputes, claims or demands for an interest of a personal nature of the reporting person that pertain exclusively to his or her individual working relationships even with hierarchically superordinate figures;
- reports of violations already mandatorily regulated by the community acts listed in Part II of the Annex to Legislative Decree 24/2023;
- the subject of national security and defense.
The whistleblower may not be discriminated against as a result of the report in accordance with the provisions of Articles 16 and 17 of Legislative Decree 24/2023, if at the time of the report he/she has good reason to believe that the information about the reported violations is true and is among the relevant ones. On the contrary, the benefit of the protection of the reporter shall be forfeited when criminal liability for the crimes of defamation or slander or, in any case, for crimes committed with the making of the report is ascertained, even by a judgment of first instance, or when the civil liability of the reporter is ascertained in cases of willful misconduct or gross negligence. Demenego S.p.A. also reserves the right to act to protect its interests in defense of the injured parties,
For the purpose of maximum protection of the guarantee of one's confidentiality, in making the report the reporter shall:
- Use only personal information devices;
- register on the online platform and make reports using a personal e-mail address.