Whistleblowing

WHAT IS IT

Whistleblowing is a breach reporting system of national or EU regulatory provisions listed in the Italian Legislative Decree no. 24 of 10 March 2023 on “the protection of persons who report breaches of Union Law and laying down rules concerning the protection of persons who report breaches of national legal provisions”, implementing Directive (EU) 2019/1937.

WHAT YOU CAN REPORT

Conduct, acts or omissions that damage the public interest or the integrity of the public administration or private entity and which consist of:

• administrative, accounting, civil or criminal offences;
• relevant unlawful conduct pursuant to Legislative Decree 231/2001, or violations of the organization and management models provided for therein;
• offences falling within the field of application of EU or national acts in the following areas: public procurement, financial services, products and markets and the prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; protection of privacy and protection of personal data and security of networks and information systems;
• acts or omissions which harm the financial interests of the Union;
• acts or omissions relating to the internal market;
• acts or conduct which frustrate the object or purpose of the provisions laid down in Union acts.

HOW TO SUBMIT A REPORT

1. Internal reporting

   a. by postal service to the address of the company headquarters
   Mixer S.p.A. via Chiara 6/C, 48012 Villa Prati di Bagnacavallo (RA).
   Report in sealed envelope, specifying the wording “MANAGEMENT – CONFIDENTIAL”.
   
   or

   b. by hand delivery to the appropriate box with the label “direzione” placed at the entrance of the Mixer S.p.A. company headquarters, Mixer S.p.A. via Chiara 6/C, Villa Prati di Bagnacavallo (RA).
   Report in sealed envelope specifying the wording “MANAGEMENT –  CONFIDENTIAL”.

The report will be managed by Mixer S.p.A. in accordance with the provisions of Legislative Decree no. 24 of 10 March 2023, implementing directive (EU) 2019/1937.

2. External reporting

Whistleblowers can use the external channel (ANAC) when:

• there is no mandatory activation of the internal reporting channel in the work context, or if this (even if mandatory) is not active or even if activated does not comply with what is required by law;
• the reporting person has already made an internal report and the same has not been followed up;
• the reporting person has reasonable grounds to believe that, if he or she were to make an internal report, it would not be effectively followed up or that the report could lead to a risk of retaliation;
• the reporting person has reasonable grounds to believe that the breach may constitute an imminent or obvious danger to the public interest.

To submit a report to ANAC – National Anti-Corruption Authority, click the following link Whistleblowing – Form for reporting unlawful conduct pursuant to Legislative Decree no. 24/2023 (anticorruzione.it)

RESOURCES AND LEGISLATIVE REFERENCES

• ANAC website, Italian language whistleblowing-www.anticorruzione.it
• European commission, Protection of Whistleblower, English language, Protection of whistleblower (Europa.eu).