Whistleblowing
Reports of alleged wrongdoing
What is whistleblowing?
Whistleblowing refers to the reporting by an individual, known as a “whistleblower,” of wrongful conduct or wrongdoing committed in the corporate environment with which he or she has a qualified relationship or engages in activity of any kind (shareholder, director, employee, self-employed person, trainee, volunteer), which he or she has witnessed or become aware of, and which is deemed detrimental to the public interest or the integrity of the company
Why is it so important to make a report?
CIM4.0 confirms its commitment to act with the highest standards of honesty and fairness.
Such a commitment is essential both for the strictest compliance with laws and regulations and for consistently winning and maintaining the trust of our customers, shareholders, employees and business partners.
In this context, CIM4.0 is committed to protecting people who report violations, as a valuable and essential contribution to the proper pursuit of the described goals.
In particular, CIM4.0 encourages prompt reporting of any action, omission, or practice deemed inappropriate or non-compliant with laws, regulations, the Organization, Management and Control Model, the Code of Ethics, and any internal policies or procedures.
The report is therefore primarily a preventive tool.
If the report is sufficiently articulated and complete, it can be verified promptly and easily, allowing the immediate adoption of the necessary steps to prevent the risk from materializing into unlawful cases or, if already in progress, to determine its immediate termination, subject to the initiation of disciplinary proceedings and possibly even recourse to the judicial authorities.
What is possible to report with Whistleblowing?
- actual or potential violations, of which it has knowledge or even reasonable suspicion,
- conduct that is alleged to be inappropriate , improper, unethical, or unlawful (or even just potentially unlawful or apparently unlawful),
- any offense, even in the form of attempt, or administrative offenses, which have occurred or are possibly verifiable, as well as the perpetrated or attempted concealment of such violations, conduct or offenses.
- corruption;
- conflicts of interest;
- money laundering, terrorist financing, or violation of sanctions;
- fraud (policy forgery, false claims, etc.);
- fraudulent financial (false accounting, etc.) or other fraudulent statements;
- threats, discrimination, physical or moral harassment, other inappropriate actions or actions contrary to corporate values and ethics;
- embezzlement (secret data, asset values, etc.), waste or misuse of assets;
- endangering health, life and safety;
- Other violations of laws, rules and regulations.
In addition to the above exemplifications, conduct attributable to the additional dedicated regulatory areas is also relevant.
What is not possible to report?
Reports may not relate to grievances of a personal nature of the reporter, claims or instances pertaining to the employment relationship.
Reports may also not be used for purposes other than those stated above or belonging to interpersonal relationships.
How can a report be made?
CIM4.0 encourages prompt reporting of any practices or actions deemed inappropriate or noncompliant.
To this end, CIM4.0 provides several communication channels (with the possibility of a possible in-person meeting) through which reporting can be done, either by name or even anonymously:
- reporting tool accessible at the link https://cim40.segnalazioni.eu/#/
It is suggested that this mode of communication be preferred as the channel is designed to ensure maximum confidentiality and security of reports and reporting parties, in compliance with applicable regulations; - local e-mail address segnalazioni.whistleblowing@cim40.com which can be accessed only by the Internal Audit manager and expressly authorized employees of the Internal Audit Function (Investigation Team); in line with regulatory dictates, it is preferable to use this channel for appointment requests aimed at verbal exposure of the report;