Who can report?

All employees, collaborators, goods and service suppliers of CONI, Coninet S.p.A. and CIP.

What to report?

1. Violations of Anti-corruption provisions, with particular reference to abuse of power by a company member for personal advantages;
2. Violations of the Organisational Modell 231, the code of ethics and the related procedures;
3. Other aspects related to fraud in the company’s internal control system and conducts in contrast with the Company non-compete clause.

The facts and circumstances that can be reported are (without being exhaustive):

• Inappropriate use of the clock-in card (e.g. the employee clocks-in and does not present to work or clocks-in for absent colleagues; the employee leaves the office or carries out personal activities during working hours);
• Receiving bribes from interested parties (e.g. suppliers, consultants, subsidy and utility recipients...), in violation with the Code of Ethics;
• The assignment of work positions or supplies for economic personal interests, nepotism or without adequate disclosure by corporate subjects that are involved directly or indirectly in the decision-making process;
• Inappropriate use or theft of company assets (e.g. cars, telephones, PC, sim cards…);
• Administrative procedures fraud to unduly favour third parties;
• Inducing or forcing suppliers/consultants/candidates to bribe for favours during negotiation procedures or in the selection process for the assignment of work positions;
• Bribery from suppliers/consultants/candidates for favours during negotiation procedures or in the selection process for the assignment of work positions.

The whistleblower must report in good faith, with concrete and detailed elements, to provide the necessary evidence to the reporting authority. Please note that the whistleblower must provide the reporting authority, structure for report management and analysis, with clear indications to start a verification and internal investigation process. The documents provided anonymously cannot be used as evidence in a possible subsequent legal dispute. Therefore, it is not necessary for the whistleblower to provide documentation.

Whistleblowers must comply with the “reporting policy”.

Who receives the reports?

The reports submitted on this platform are forwarded as strictly confidential to the appointed Department, which notifies the Authorities in charge.

Does the whistleblower identity remain confidential while reporting?

Yes. Whistleblowing platform preserves the confidentiality of the whistleblower identity when submitting a report. Reporting authorities cannot access the identification data of the whistleblower.

Does the whistleblower personal data remain confidential during investigation?

Yes. The whistleblower and the reporting Authority can interact through this portal in conditions of anonymity.

Do anonymous reports qualify?

The platform accepts both nominative and anonymous reports.

The platform allows overcoming the limitations of traditional anonymous reporting, which does not consent to verify and investigate better on the facts. It enables to establish a protected dialogue with the whistleblower through randomly generated credentials and not attributable to the whistleblower.

The identity of the whistleblower is confidential in any subsequent context except when reporting libellous and defamatory information. The identity of the whistleblower may be revealed to the disciplinary authority and to the accused only after the whistleblower’s consent.

Furthermore, if the whistleblower’s identity is essential for the defence of the accused, the report will be used in the disciplinary procedure only after the whistleblower’s consent.

In which cases is it possible to trace the identity of the whistleblower?

Without prejudice to the above, the identity of the whistleblower may be revealed in the following cases:

- Request from legal/supervisor authorities or legal obligations.

- Disingenuous, offensive, libellous, and defamatory reports.

Are there any provision against whistleblowers that submit disingenuous, offensive, libellous, and defamatory reports?

Yes. Employees and collaborators that submit disingenuous, offensive, libellous, and defamatory reports are subject to penalty measures, in accordance with the collective agreement (CCNL).

What is a detailed reporting?

A “detailed” report allows to identify in detail all the objective elements that enable the investigation start up, such as: methods and purposes of misconduct or breach, period of the violation, the people involved, damage quantification, methods of control system fraud, copy of the referred documentation, etc.

What is a disingenuous report?

A disingenuous report has an artificial structure in order to appear objective and detailed. It actually conceals the intention of the whistleblower to damage the accused for personal or third parties interests or for no reason at all.

Detailed reports that result to be false but made in good faith are not considered “disingenuous” reports.

Is it possible to attach documentation to the report?

Yes. However, documents, photos, videos, and audio registration that represent a violation of the privacy confidentiality or other personal rights will not be taken into consideration. The same applies to defamatory documentation that may be subject to disciplinary measures from the competent authorities.

Do the top Managers get involved in the investigation outcome?

Yes. The CEO takes the necessary action in relation to the report and communicates the necessary information to the competent Authorities.