Whistleblowing

DF SRL has established the Whistleblowing Portal for those who wish to report, in good faith, any of the following behaviors, acts, or omissions:

  1. administrative, accounting, civil, or criminal offenses;
  2. unlawful conduct relevant under Legislative Decree 231/2001 or violations of organizational models;
  3. offenses that fall within the scope of application of EU or national acts (public procurement; services, products, and financial 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; privacy and personal data protection and network and information system security);
  4. acts or omissions that harm the financial interests of the EU, protected under Article 325 TFEU;
  5. acts or omissions concerning the internal market, referred to in Article 26 paragraph 2 TFEU, including violations of EU competition and state aid rules as well as corporate tax laws;
  6. acts or behaviors that undermine the object or purpose of the provisions of the EU acts in the sectors indicated in points c), d), and e);
  7. information relating to conduct aimed at concealing the aforementioned violations;
  8. illegal activities not yet carried out but which the whistleblower reasonably believes may occur in the presence of concrete, precise, and consistent elements;
  9. well-founded suspicions.

Reports must be made to protect the integrity of the Company and must be based on precise and consistent factual elements.

METHOD OF REPORT TRANSMISSION

Access to the Portal is managed in no-log mode, in order to prevent the identification of the whistleblower who wishes to remain anonymous.

After access, the whistleblower will be guided in completing a questionnaire consisting of open and/or closed questions that will allow providing the elements characterizing the report (facts, temporal context, etc.).

At the end of the questionnaire, the Portal will ask the whistleblower whether they wish to provide their identity. In any case, the whistleblower can provide their details at a later time, always through the Portal.

At the time of sending the report, the Portal will issue the whistleblower a unique identification code (ticket). This number, known only to the whistleblower, cannot be retrieved in any way in case of loss. The ticket will serve the whistleblower to access, through the Portal, their report in order to: monitor its progress; provide additional elements to substantiate the report; provide their details; respond to any follow-up questions. The Portal allows, in fact, to establish a virtual dialogue (chat) between the whistleblower and the recipient, if desired, always in a completely anonymous form.

WHO MANAGES THE REPORT

The task of managing the reports is entrusted to the Supervisory Body of DF SRL.

PROTECTION AND RESPONSIBILITY OF THE WHISTLEBLOWER

No retaliation or discrimination, direct or indirect, can result against those who have made a report in good faith. Moreover, sanctions are foreseen against those who violate the whistleblower protection measures.

Sanctions are foreseen against the whistleblower, where possible, in case of reports made with malice or gross negligence or that are found to be false, unfounded, defamatory, or otherwise made solely to harm the Company, the reported person, or subjects involved in the report. The Company may also take appropriate actions, including legal proceedings.

PROTECTION OF THE REPORTED PERSON

The report is not sufficient to initiate any disciplinary proceedings against the reported person. If, following concrete findings acquired regarding the report, it is decided to proceed with the investigation, the reported person can be contacted and will be guaranteed the right to provide any necessary clarification.

PRIVACY PROTECTION

Any personal and sensitive data contained in the report, including those relating to the identity of the whistleblower or other individuals, will be processed in full compliance with EU and national data protection regulations.

PROCEDURE TO FOLLOW

For greater awareness of how DF SRL handles any reports, please refer to the “Whistleblowing Policy” Procedure downloadable within the Platform.

SEND A REPORT

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