Prestige Italia S.p.A. (hereinafter, “Prestige Italia” or the “Company”) is committed to operating in an ethical and responsible manner, and requires those in its organization (directors, executives, managers, employees and other associates) and its business partners to act accordingly.
Therefore, also in order to protect its values, Prestige Italia supports and encourages reports of potential violations of national and European regulatory provisions of which there is certain knowledge or reasonable suspicion, provided that the report is based on precise and concordant factual elements. Everyone is invited to promptly report illicit conduct and irregularities, or any acts and omissions aimed at concealing them, in order to allow them to be stopped in time and action to be taken against their authors. Inadequate handling of reports may result in the risk of legal action or sanctions for Prestige Italia, as well as negative impacts on its image and reputation.
To this end, Prestige Italia has implemented specific rules and a whistleblowing procedure for the handling of reports of wrongdoing (“Whistleblowing Policy” or “Policy”) to provide whistleblowers with secure channels that guarantee the confidentiality of their identity as well as of the information contained in the report and their protection against any retaliation. The full Policy is available at www.prestigeitalia.com.
WHO CAN MAKE A REPORT?
Whistleblowers may be the following individuals who work for the Company:
even when the legal relationship has not yet begun, if information on breaches was acquired during the selection process or during other pre-contractual stages, or during the probationary period, or after the end of the legal relationship, if such information was acquired during the course of the relationship.
WHAT CAN BE REPORTED?
Prestige Italia strongly encourages its stakeholders to report any violation of Italian and/or European Union regulations, even if not yet committed, of which they have become aware in the context of their work and referring to one or more of the following matters:
(i) public procurement;
(ii) financial services, products and markets and prevention of money laundering and terrorist financing;
(iii) product safety and compliance;
(iv) transport security;
(v) protection of environment;
(vi) radiation protection and nuclear safety;
(vii) food and feed safety, animal health and welfare;
(viii) public health;
(ix) consumer protection;
(x) protection of privacy and personal data and security of network and information system security
WHAT SHOULD NOT BE REPORTED?
The following will not be dealt with:
WHAT SHOULD BE SPECIFIED IN THE REPORT?
The report must:
HOW CAN A WHISTLEBLOWING REPORT BE MADE?
The Company has provided internal channels that guarantee the confidentiality of the whistleblower, of the person reported and/or otherwise involved in the report, and of the content of the report. The management of internal channels is entrusted to a competent, autonomous, trained external party, specifically appointed by Prestige Italia (“Case Manager”).
The whistleblower can submit a report through the IT platform “Whistle365” (“Platform”), which is provided by a specialized external service provider and can be accessed through a link from www.prestigeitalia.com.
The Platform allows the submission of written or oral reports, according to the instructions accessible from the link https://whistleprestige.prestigeitalia.com/.
The whistleblower may make a written report by registered mail with return receipt.
For this purpose, the report should be placed in two sealed envelopes, including, in the first, the identifying data of the reporter and, in the second, the subject of the report. Both envelopes should then be placed in a third envelope addressed to:
Prestige Italia S.p.A. c/o Ms. Monica Zanni, Attorney
Villa Loschi Zileri – Via Battaglione Val Chiese, 10
36100 Vicenza (VI)
RESTRICTED to the Case Manager of the whistleblowing reporting channel.
The whistleblower can request a face-to-face meeting via the Platform or the written report. The Case Manager will give feedback by informing the reporter regarding the place and manner of the requested face-to-face meeting.
CAN A REPORT BE MADE ANONYMOUSLY
Reports from which the identity of the whistleblower cannot be determined are considered anonymous.
Although anonymous whistleblowing reports are accepted, the Company encourages whistleblowers to submit reports bearing their names, in order to streamline investigations and make them more effective.
The Case Manager follows up on anonymous reports where they are adequately substantiated and rendered with full details, that is, they are able to bring out facts and situations by relating them to specific contexts.
WHAT DOES PRESTIGE ITALIA DO AFTER RECEIVING THE WHISTLEBLOWING REPORT?
The Case Manager proceeds by giving feedback to the whistleblower as follows:
The external reporting channel is activated at the National Anticorruption Authority (ANAC) https://www.anticorruzione.it/.
The whistleblower may submit an external whistleblowing report only if, at the time of its submission:
The whistleblower may make a public disclosure if:
REPORT TO THE JUDICIAL OR ACCOUNTING AUTHORITY
In any case, the whistleblower has the option of making a report to the Judicial or Accounting Authority in cases where European Union or national law requires that the matter be referred to the competent national authorities because, for example, the violation constitutes a crime.