Whistleblowing

The fundamental principles of Sisal's reporting system

1. Protection of the identity of whistleblowers and the confidentiality of information
   Sisal guarantees the protection and confidentiality of the identity of the whistleblower. The whistleblower's data are processed in accordance with the law and adopting any useful measure to prevent the dissemination of the whistleblower's data and the content of the report. The identity of the whistleblower shall not be disclosed – without his or her explicit consent – to anyone other than the authorized staff competent to receive and follow up on reports, unless disclosure is a necessary and proportionate obligation imposed by EU or national law. In such cases, the whistleblower shall be notified, by written communication, of the reasons for the disclosure of the confidential data. In addition, reports are exempt from the right of access provided, and as far as applicable to the private sector, by art. 22 et seq. of Law no. 241/1990, as well as by art. 5 et seq. of Legislative Decree no. 33/2013.
2. Prohibition of retaliatory or discriminatory acts against whistleblowers
   Sisal prohibits any form of retaliation or discrimination, active or omissive, even if only attempted or threatened, carried out because of the report and which causes or may cause unjust damage to the whistleblower, directly or indirectly. This protection is guaranteed if the report (even if subsequently assessed as unfounded) was made in good faith. Sisal guarantees the removal of the effects of any form of retaliation against the whistleblower. The commission of retaliatory or discriminatory acts against any person who has made a report shall result in disciplinary proceedings being initiated against the perpetrator of such acts and the imposition of the relevant disciplinary measures (which may also entail dismissal), in accordance with the provisions of the applicable national labor law, and shall be reported to the competent authorities, in accordance with the provisions of the applicable legislation, and those responsible for those responsible may be subject to civil and criminal penalties. The measures to protect reporting persons also apply, where appropriate, to other entities and situations (e.g. facilitators, i.e. those who assist the whistleblower in the reporting process, or to third parties connected with the whistleblower and who could risk retaliation, such as colleagues or relatives of the whistleblower).
3. Protection of the reported person
   The reported persons are protected both regarding the confidentiality of the reports concerning them and any investigations carried out, and the protection of the same from any retaliatory and/or defamatory actions. Following investigations into the merits of the report, the Whistleblowing Committee, i.e. the body responsible for receiving, analyzing, investigating and responding to reports, if disciplinary proceedings are opened, informs the person to whom the report refers, keeps him or her updated on the progress of the procedure, compatibly with the performance of the verification activities and the collection of the necessary evidence, so as to allow him to exercise the right of defense.
4. Protecting the integrity of reports
   The reporting channels made available by Sisal guarantee that no report (from the notification phase to the decision) can be deleted and/or altered.
5. Duty of independence and professionalism in the management and assessment of reports
   All parties involved, in any capacity, in the process of managing and evaluating reports must carry out the related tasks in compliance with the duties of independence and ensuring the accurate and efficient management and evaluation of all reports. In particular, the body responsible for managing reports is autonomous, dedicated and composed of personnel specifically trained for this activity.

How to report

• web platform Speak Up
• registered telephone line/voice messaging system accessible 24/7 at the following telephone number 800761667
• direct meeting with the Whistleblowing Committee, with the possible involvement of the Supervisory Body (Organismo di Vigilanza, ODV) in the case of relevant reports pursuant to Legislative Decree 231/2001.

The golden rules for good reporting

Reports can be made anonymously, but, in any case, they must be made in good faith and provide all the elements known to the whistleblower, useful for proceeding with the due and appropriate checks to verify the validity of the facts being reported.

Conflict of interest management

Sisal pays great attention to ensuring that the management and evaluation of reports are entrusted exclusively to parties who are not in situations of conflict of interest. Therefore, specific methods are identified for the management of reports that refer to one, more or all the members of the Whistleblowing Committee. These provisions also apply if the conflict should arise during the investigations.