Whistleblowing
Aindo S.p.A. (“Aindo”) has adopted a Code of Ethics and a compliance program (“231 Model”) pursuant Legislative Decree 231/2001 and has implemented an internal reporting system (hereinafter also referred to as “Whistleblowing”) to allow the reporting of potential violations of corporate regulations and national and European legislative provisions, in compliance with Legislative Decree 24/2023 and EU Directive 2019/1937. The objective is to promote a corporate culture based on ethics, transparency, and compliance with current regulations.
1. Scope of Application
Aindo’s Whistleblowing system allows employees, collaborators, and third parties to report any violations they become aware of while performing their duties through dedicated channels. Reports can be submitted either nominally or anonymously, ensuring in all cases the confidentiality of the whistleblower’s identity and compliance with the protections provided by law.
Reports may concern, by way of example:
- Violations of the 231 Model pursuant to Legislative Decree 231/2001;
- Acts of corruption and offenses against the Public Administration;
- Fraud, abuse, or unlawful conduct harming the Company or third parties;
- Violations concerning personal data protection (GDPR and Privacy Code);
- Undisclosed conflicts of interest;
- Violations in competition or financial matters;
- Discrimination, harassment, or behavior detrimental to personal integrity.
Reports of a personal nature or unrelated to corporate misconduct do not fall within the scope of the Whistleblowing system and will not be considered.
2. Reporting Channels
Aindo provides the following channels for submitting reports:
- An online reporting platform, accessible at the designated corporate address, available 24/7, and managed by an independent provider to ensure confidentiality;
- A one-on-one meeting with the Supervisory Body, by appointment requested via email at the dedicated address: [email protected].
The Supervisory Body is in charge of the management of the whistleblowing reports.
3. Confidentiality Protection and Prohibition of Retaliation
Aindo ensures the highest confidentiality of received information, protecting the identity of the whistleblower and the individuals involved. Every report will be handled impartially and independently, in accordance with the Whistleblowing Decree and GDPR provisions.
The Company expressly prohibits any act of retaliation or discrimination against the whistleblower and those providing information or assistance in the investigation process. Any violation of this prohibition will be subject to disciplinary measures and, if necessary, reporting to the competent authorities.
4. Report Management
The report management process includes the following stages:
- Receipt and registration of the report, with acknowledgment of receipt within seven days;
- Preliminary assessment to determine the admissibility of the report;
- Investigation for gathering and analyzing information, ensuring fairness and impartiality principles;
- Outcome and actions, with feedback to the whistleblower within three months and, if necessary, corrective measures.
All information will be recorded and retained for the strictly necessary period, in compliance with applicable regulations.
5. Training and Awareness
Aindo is committed to promoting a Whistleblowing culture through periodic training and awareness activities for all employees and collaborators to ensure knowledge of procedures and the importance of reporting misconduct.
For further details, please refer to the Whistleblowing procedure.
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