Whistleblowing reports

Giflor Srl recognizes the importance of establishing effective reporting channels to safeguard the integrity of the Company, ensuring compliance with the fundamental principles of legality, fairness, and transparency.

This commitment also extends to relationships with third parties in the course of conducting business activities.

Transparency and clarity in the handling of reports are essential to fostering an ethical and responsible corporate environment.

Giflor is committed to ensuring confidentiality and protection against retaliation for individuals who submit reports in good faith.

What is whistleblowing?

Whistleblowing reports concern suspected violations of national and European Union laws and regulations that individuals have become aware of in the context of their work activities, thereby contributing to the identification and prevention of conduct that may undermine proper administration or the public interest.

In accordance with Legislative Decree No. 24/2023, transposing EU Directive 2019/1937, Giflor Srl has established dedicated internal whistleblowing reporting channels.

What types of behavior can be reported?

“Relevant Reports” shall include any reports concerning conduct, acts, or omissions occurring in a work-related context that harm the public interest or compromise the integrity of the Company, including, but not limited to:

Unlawful conduct pursuant to Legislative Decree No. 231/2001 and violations of the Company’s Organizational, Management and Control Model (“Model 231”), such as corrupt practices involving Public Administration, breaches of occupational health and safety regulations, and violations of environmental legislation. Such reports may be submitted exclusively through the internal reporting channels;
Breaches falling within the scope of European Union acts relating to the following sectors: public procurement; financial services, products and markets, and the prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; public health; consumer protection; protection of privacy and personal data; and security of network and information systems;
Acts or omissions affecting the financial interests of the European Union, including fraud, corruption, and any other illegal activities connected to Union expenditure;
Acts or omissions relating to the internal market, including violations of EU competition law and State aid rules, as well as rules concerning corporate taxation and the free movement of goods, persons, services, and capital;
Acts or conduct that defeat the object or purpose of the provisions set out in European Union acts in the sectors mentioned above, such as abusive practices that undermine fair competition (e.g., predatory pricing, target rebates, tying arrangements, etc.).

The following shall not be considered whistleblowing reports: reports relating to a purely personal interest of the reporting person that concern exclusively their individual employment relationship; unfounded allegations; information already fully in the public domain; information acquired solely on the basis of rumors or hearsay; or reports that are manifestly pretextual, defamatory, or intended to harm the reported person.

Who can submit a report?

The following persons operating within the Company’s work-related context may submit a report:

Employees;
Self-employed workers and collaborators who carry out their professional activities within the Company;
Freelancers and consultants providing services to the Company;
Volunteers and trainees, whether paid or unpaid, who perform activities within the Company;
Persons performing administrative, management, supervisory, control, or representative functions within the Company, including where the legal relationship has not yet commenced, if the information concerning violations was acquired during the recruitment process or other pre-contractual stages, during the probationary period, or after termination of the legal relationship, provided that the information was obtained in the course of the relationship.

How to submit an internal report

Internal collaborators, members of corporate bodies, or external individuals (such as consultants, freelancers, trainees, etc.) may submit reports in a confidential or anonymous form through two main channels (written and oral):

Online Whistleblowing Reporting Platform – https://giflor.signalethic.it
Telephone lines available from Monday to Friday, from 09:00 a.m. to 6:00 p.m., at the following numbers:
+39 328 7514819 – +39 327 3240442, with forwarding to the Channel Managers. In order to ensure confidentiality, the reporting person must immediately state that they intend to submit a “Whistleblowing Report”.

Upon request of the reporting person, it is also possible to arrange a direct meeting with the Channel Manager. Such meeting shall be conducted exclusively by the Channel Manager under confidential conditions and documented through the completion of a reporting form.

In compliance with the Whistleblowing Decree (Legislative Decree No. 24 of 10 March 2023), the reporting channels indicated above guarantee the utmost confidentiality regarding the identity of the reporting person, the person concerned, and any other individuals mentioned in the report, as well as the content of the report and the related documentation. The management of the reporting channel is entrusted to Mr. Marco Borsato and Mr. Denis Dalla Fontana (the “Channel Managers”).

Where the conditions expressly provided for by Legislative Decree No. 24 of 10 March 2023 are met, the reporting person may submit an external report to ANAC (Italian National Anti-Corruption Authority) under the same procedures and guarantees applicable to internal reporting: www.anticorruzione.it/whistleblowing.

How are reports handled?

the Channel Manager shall carry out the following activities:

acknowledge receipt of the report to the reporting person within seven days from the date of receipt;
maintain communication with the reporting person and, where necessary, request additional information;
follow up on the reports received by involving the persons or functions responsible for handling the report;
provide feedback to the reporting person within three months from the date of the acknowledgment of receipt or, in the absence of such acknowledgment, within three months from the expiry of the seven-day period following submission of the report.

For the proper handling of the report, internal or external parties may be involved, depending on the specific technical and professional expertise required, provided that they are not in a conflict of interest and are bound by the confidentiality obligations set out by applicable law.

At the conclusion of the preliminary assessment, if the report is found to be well-founded, the Channel Manager shall refer the matter to the competent internal bodies or functions in order to initiate any appropriate preventive, corrective, or disciplinary actions against the reported person.

The Channel Managers are:
Marco Borsato – +39 328 7514819
Denis Dalla Fontana – +39 327 3240442

The Whistleblowing Policy is available in full at the link below and is intended to provide all necessary information regarding the available reporting channels, the procedures to be followed, and the conditions for submitting both internal and external reports.

Personal data will be processed in accordance with Regulation (EU) 2016/679 (GDPR) and Legislative Decree No. 24/2023.
For further information, please refer to the Whistleblowing Privacy Notice.

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