Agile Idea Atom Versione 2.0

BB Quadrilatero s.r.l. has activated, as provided for by Legislative Decree no. 24 of 10 March 2023 implementing Directive (EU) 2019/1937 of 23 October 2019, its own internal whistleblowing reporting channel.

This channel aims to protect persons, who have or have had a legal relationship with BB Quadrilatero s.r.l., who report violations of EU and national law provided for by the aforementioned Decree. Reports must therefore be relevant to the provisions of the legislation and circumstantiated, within the required limits. The reports will be handled by an internal office of the company. dedicated to the management of the reporting channel, whose members are authorised to process the data pursuant to Articles 29 and 32 of Regulation (EU) 2016/679 (so-called GDPR). BB Quadrilatero s.r.l. undertakes to protect whistleblowers, guaranteeing their confidentiality and the prohibition of retaliatory acts. It is specified that such protection ceases in the event of unfounded reports made with malice or gross negligence. In this regard, please note that sanctions are provided for those who are found liable for the offences of defamation or slander.

Whistleblowing is a tool that allows employees or third parties of a company to report, in a confidential and protected manner, any wrongdoing encountered in the course of their work. With Legislative Decree 24/2023, Italy transposed EU Directive 2019/1937 on whistleblowing, with the aim of guaranteeing a high level of protection for those who make the above-mentioned reports.

Conduct, acts or omissions that harm the public interest or the integrity of the public administration or private entity and that consist of: administrative, accounting, civil or criminal offences; unlawful conduct relevant pursuant to Legislative Decree 231/2001, or violations of the organisation and management models provided for therein; offences that fall within the scope of application of European Union or national acts relating to the following areas: public procurement; services, products and financial markets and the prevention of money laundering and the financing of terrorism; 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; privacy and the protection of personal data and the security of networks and information systems; acts or omissions that harm the financial interests of the Union; acts or omissions concerning the internal market; acts or conduct that frustrate the object or purpose of the provisions set out in the Union acts.

The system must not be used for unfounded reports. A report must be based on valid information and must be made in good faith. The report or public disclosure must be made using the channels provided (internal, external and public disclosure)

Reporting through this system is secure and guarantees the confidentiality of the identity of the whistleblower and of any other person mentioned in the report. The confidentiality of the whistleblower is ensured: by ensuring that the identity of the whistleblower is not disclosed except with the whistleblower's consent and in the cases provided for therein (criminal proceedings, disciplinary proceedings, accounting proceedings); by providing that the discipline under review is removed from the possibility of administrative access by providing due authorisations to the persons receiving the reports and binding them to strict confidentiality obligations

The handling of the report consists of notifying the reporting person of the receipt of the report within 7 days from the date of its receipt, unless explicitly requested otherwise by the reporting person or unless the ANAC considers that the notice would undermine the protection of the confidentiality of the identity of the reporting person; maintaining interlocutions with the reporting person and requesting additions from the latter, if necessary; diligently following up the reports received carry out the necessary preliminary investigation to follow up the report, also by means of hearings and acquisition of documents; provide feedback to the person making the report within 3 months or, if there are justified and substantiated reasons, 6 months from the date of receipt of the external report or, in the absence of such notice, from the expiry of 7 days from receipt; notify the person making the report of the final outcome of the report.