Whistleblowing is the tool that allows you to report violations or suspected violations of which you become aware during the course of your work activity. In implementation of Legislative Decree 10 March 2023, n. 24, PAC S.p.A. has equipped itself with the prescribed channels for receiving and managing reports called "whistleblowing".
Reporters may be: shareholders, people with administrative, management, control, supervisory or representation functions of PAC S.p.A., even if these functions are exercised on a purely de facto basis. As well as employed workers, interns, self-employed workers, freelancers and consultants who work for the Company. Finally, subjects who have held the roles indicated above in the past, if the information on the violations was acquired during the relationship and subjects with whom the relationship has not yet arisen - for example candidates for personnel selection or employees during the period test.
The list of matters subject to reporting is very detailed and complex, for completeness please refer to Legislative Decree 24/2023. In general, violations of European Union regulatory provisions which harm the public interest or the integrity of the Company, of which the reporting person has become aware in the work context, consisting of: illicit conduct relevant to the pursuant to Decree 231 or violations of Model 231; offenses that fall within the scope of application of European Union or national acts or of national acts that constitute the implementation of European Union acts on public procurement; financial services, products and markets and 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 that harm the financial interests of the European Union referred to in art. 325 of the Treaty on the Functioning of the European Union; acts or omissions concerning the internal market, referred to in art. 26, par. 2, T.F.U.E. (including competition and state aid infringements and corporate tax infringements); acts or conduct which, while not amounting to an offence, frustrates the object or purpose of the provisions of the Union acts in the sectors indicated above.
Illegal conduct relevant pursuant to Legislative Decree 231/2001 or violations of Model 231 adopted by the Company are also subject to possible reporting.
Sending an internal report
Those who wish to make an internal report, also requesting to remain anonymous, can forward it via the following channels adopted by PAC S.p.A.:
- the toll-free number 800 689257 which is answered by an automated voice messaging service for the collection of oral reports;
-the platform https://pacspa.wb.teseoerm.com to which written reports and, if applicable, attached documents can be sent.
This is without prejudice to the right of the whistleblower to request a direct meeting - by videoconference or telephone - with the Supervisory Body, appointed as manager of the reporting channels. The request for a direct meeting must be formulated using one of the channels - vocal or in writing - indicated above.
The whistleblower is invited to attach all the documentation proving the facts reported, refraining from undertaking independent analysis and in-depth initiatives.
Where a report containing serious, precise and consistent elements concerns a member of the Board of Auditors, the inspection and decision-making activities will be assumed and carried out by the other members of the Board, provided that they represent the majority.
In this case, it will be the responsibility of the President and/or another auditor (depending on the member reported) to inform the President of the Board of Directors who will be able to participate in the Board meeting on the matter to guarantee the correctness of the processes and decisions, also towards the member reported.
Where the report containing serious, precise and consistent elements concerns more than one member of the Board of Auditors, the Board of Directors will be competent - and, if necessary, the Shareholders' Meeting.
Sending an external report
External reports can be made in written form via the IT platform set up by ANAC or in oral form via telephone lines or voice messaging systems or, at the request of the reporting person, through a direct meeting.
The link for the platform is available on the ANAC website: https://www.anticorruzione.it/