Whistleblowing: A Guide to Corporate Safety and Integrity

1. Introduction

SER S.p.A. is committed to promoting an ethical and transparent work environment, where legality, transparency, and accountability are fundamental values. In this context, whistleblowing represents an essential tool for identifying and preventing unlawful conduct, ensuring protection for employees and other individuals who, in good faith, report any irregularities.

2. Purpose and Scope

The purpose of this notice is to outline the procedures and guarantees provided by SER S.p.A. for the handling of reports concerning unlawful conduct or non-compliance with applicable regulations. This policy complies with Legislative Decree No. 24/2023, which implements EU Directive 2019/1937 (the European Whistleblowing Directive), and applies to all SER S.p.A. employees, collaborators, suppliers, and other stakeholders who have relations with the company

3. Legal References

Legislative Decree 24/2023: Implements EU Directive 2019/1937, defining the necessary measures for the protection of individuals reporting violations of Union law and national laws in specific sectors.
EU Directive 2019/1937: ets out minimum standards for the protection of whistleblowers who report breaches of Union law in areas such as anti-corruption, personal data protection, consumer health and safety, and more.

4. Definitions

Whistleblower: n individual who, having become aware of unlawful or irregular conduct, chooses to report it through the whistleblowing procedures.
Report: any communication, including anonymous ones, concerning acts or omissions that may constitute violations of laws, company regulations, or the SER S.p.A. Code of Ethics.
Violations: acts or omissions in breach of laws, corporate regulations, or ethical and professional standards.

5. Reporting Procedures

SER S.p.A. provides a certified and secure channel for whistleblowers to submit their reports. The platform is called “Wallbreakers” and can be accessed at the following link: https://ser.wallbreakers.it

6. Whistleblower Protection

SER S.p.A. si impegna a garantire la massima tutela nei confronti del whistleblower, in particolare attraverso:

Protection against retaliation: Any form of retaliation or discrimination against the whistleblower is strictly prohibited, including dismissal, demotion, harassment, unwanted transfers, or any actions that could harm their professional standing.
Confidentiality: Information relating to the whistleblower and the content of the report will be treated confidentially and shared only with strictly necessary authorized personnel.
Anonymity: SER S.p.A. allows anonymous reports, ensuring a reporting system that does not require the whistleblower to be identified, in compliance with applicable legal provisions.

7. Handling of Reports

Reports received are handled impartially and promptly. The Compliance Officer, or a specifically appointed Committee, assesses the report and initiates the necessary investigations. If the report is substantiated, disciplinary actions or corrective measures will be taken to address the identified irregularities.

8. Anti-Retaliation Obligations and Sanctions

In compliance with Legislative Decree 24/2023, SER S.p.A. takes action against anyone who engages in retaliatory behavior toward the whistleblower. Sanctions are also foreseen for anyone who hinders reporting or misuses the whistleblowing tool by submitting false or malicious reports.

9. Training and Awareness

SER S.p.A. is committed to training its employees on the rights and obligations established by whistleblowing regulations, in order to foster a corporate culture based on ethics and transparency. Regular training and information sessions will be held to ensure awareness of the whistleblowing system.

10. Responsibility and Oversight

The Compliance Officer is responsible for monitoring the whistleblowing system, ensuring that reports are managed appropriately and in accordance with current regulations. Periodic audits will be conducted to evaluate the system's effectiveness and propose any necessary improvements.

11. Policy Revisions

This policy may be subject to periodic updates to reflect regulatory changes or to improve the reporting management system. The most recent version will be made available to all employees and interested parties.

12. Contact Information

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