Here you will find answers to the most common questions you may have about the Whistleblowing Management System and its use.
Any person inside or outside Gemelli Isola may send a Report to the Supervisory Board. Whistleblowers, by way of example but not limited to, may be:
- Members of the Board of Directors and the Board of Auditors;
- Employees, Collaborators and Consultants;
- Interns, Suppliers and individuals who have had or intend to have relations with the Company.
The Reporting may concern conduct that does not comply with legal regulations (both national and European) and the principles contained in the Code of Ethics, Model 231 and, more generally, in all the Company’s internal regulations (regulations, procedures, operating instructions). In order to enable the useful performance of fact-finding activities, the Whistleblower must report, in good faith, any relevant information of which he or she has become aware in the context of his or her own work context and which allows appropriate verification to be carried out.
No, access to the digital platform allows for the submission of Reports without a registration requirement.
At the end of the Whistleblowing Report, the system processes a code that must be noted by the Whistleblower in order to re-enter the platform, check the processing status of the Whistleblowing Report, and to consult and send any messages to those in charge of the Whistleblowing Report management channel.
Yes, the system allows the submission of completely anonymous Reports. In case the Reporting person decides to provide his or her personal details, the same is guaranteed in terms of confidentiality and protection from retaliation or discrimination.
The Supervisory Board represents the recipient of all Reports.
All parties involved in the analysis and evaluation of Reports are obliged to ensure the protections provided for the Reporting Party, the Reporting Party and all parties involved in the Reporting as provided for in the current legislation (Legislative Decree of 10.03.2023 No. 24).
The Reporting, within the IT platform, is correctly sent at the end of the procedure of “sending Reporting” i.e. when the Reporting person, having completed the completion of the required fields, clicks on the “Send” button. Following this action, the data are registered in the system. If the Reporting Person does not complete the Reporting process by clicking on the “Send” button the Reporting is not registered and all data in it will be lost.
Yes, the Reporter can access the platform at any time after submission using the code of the Report to check its processing status.
Gemelli Isola guarantees the confidentiality of the identity of the Whistleblower and the persons involved in the Report, starting from the stage of receiving the Report, in compliance with the provisions of the law. The confidentiality of the identity of the Whistleblower is guaranteed by procedural and IT measures to protect him/her and by a no-log policy that does not allow any direct or indirect way of detecting information about the mode of connection (e.g., server, IP address), even if it is made through a PC connected to a corporate network. Those in charge of the Whistleblowing channel and any relevant structures involved in the investigation phase are required to ensure confidentiality on the existence and content of the Whistleblowing Report, as well as the identity of the Whistleblower, the Whistleblower and all persons involved.
Gemelli Isola guarantees, in accordance with applicable regulations, the protection of anyone who makes a Report in good faith from retaliatory actions or any discriminatory measures related, directly or indirectly, to the Report itself.
The guarantees of confidentiality provided by the procedure also protect the Whistleblower. In addition, the Whistleblower will not be disciplined in the absence of objective findings about the reported violation, ascertained in accordance with the relevant applicable regulations.
For any further information regarding the rights of the Whistleblower and the Whistleblower, the persons involved, the procedures for handling Reports and any additional regulatory provisions, please refer to the consultation of Legislative Decree 24 of 10.03.2023 and the ANAC website at the following link: https://www.anticorruzione.it/-/whistleblowing or write to gm.odv@fbf-isola.it
