Whistleblowing
In accordance with Directive (EU) 2019/1937, Legislative Decree No. 24 of March 10, 2023, concerning "the protection of persons reporting breaches of Union law and containing provisions on the protection of persons reporting violations of national legislative provisions" (Whistleblowing), has been issued.
Metal Work S.p.A. (hereinafter the "Company") has implemented the "Whistleblowing" system provided for by Legislative Decree No. 24/2023. Below is an excerpt from the Whistleblowing reporting procedure, available in PDF format for public access.
Reporting Party
- employed persons;
- self-employed individuals, holders of collaboration agreements, freelancers, and consultants;
- volunteers and interns, whether paid or unpaid;
- shareholders and individuals with administrative, managerial, supervisory, oversight, or representational functions (even in fact);
- workers or collaborators performing their work activities at third-party entities providing goods or services or carrying out work on behalf of the Company.
Subject of the report
- Violations falling within the scope of application of acts of the European Union or national acts indicated in the Annex to Legislative Decree No. 24/2023, violations falling within the scope of application of national regulations implementing acts of the European Union in the sectors mentioned in the Annex to Directive 2019/1937 (public procurement; services, products, and financial markets, prevention of money laundering and terrorist financing; product safety and conformity; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; privacy and personal data protection and the security of networks and information systems).
- Acts or omissions that harm the financial interests of the Union pursuant to Article 325 of the Treaty on the Functioning of the European Union (TFUE).
- Acts or omissions concerning the internal market.
- Acts or behaviours that undermine the purpose or objectives of the provisions of Union acts in the sectors mentioned in the previous points.
- Acts or omissions that harm financial interests.
- Unlawful conduct (or suspected unlawful conduct) relevant under Legislative Decree No. 231/2001.
- Unlawful conduct (or suspected unlawful conduct) relevant because they do not comply with the Ethical Code, policies, and procedures adopted by the Company.
Actions, facts, and behaviours that can be reported
With the aim of aiding the reporter in identifying the incidents that can be subject to reporting, the following is a non-exhaustive list of relevant behaviours, provided as examples:
- violation of the Organization, Management, and Control Model and the Ethical Code adopted by the Company;
- offering a sum of money or granting other benefits to a public official or someone tasked with public service as a counterpart for the exercise of their functions (e.g., expediting a procedure) or for performing an act contrary to their official duties (e.g., failure to issue a citation for tax irregularities);
- promise or giving of money, goods, services, or other benefits aimed at corrupting suppliers, certification institutions, sponsors, or other entities with which the company collaborates;
- acceptance of money, goods, services, or other benefits from suppliers/other entities in exchange for favours or disloyal behaviour;
- unlawful agreements with suppliers, consultants, clients, sponsors (e.g., issuing fake invoices, price-fixing agreements, etc.);
- falsification, alteration, destruction, or concealment of documents;
- irregularities in accounting, administrative, or tax compliance, or in the preparation of the Company's financial statements;
- falsification of expense reports (e.g., inflated reimbursements or for fictitious business trips);
- theft of money, valuables, supplies, or other assets belonging to the Company;
- unauthorized disclosure of confidential information;
- computer fraud;
- harassment.
The entity responsible for receiving reports
DOES NOT carry out activities of investigation or resolution of subjective and personal issues of the reporting party, nor can affect, except indirectly and mediated, on them;
CANNOT replace competent authorities in the relevant field;
DOES NOT handle reports from private entities, trade unions, as well as from individuals other than those specified above.
