Whistleblowing

The whistleblowing portal
Tecno SpA (the "Company") makes the Whistleblowing Portal (the "Portal") available to those who intend to report, in good faith, conduct or events that may constitute violations of laws or regulations (national or European Union), or company procedures or in any case not compatible with ethically correct behavior. Reports must be made to protect the public interest and the integrity of companies.

How to transmit the report
The Portal allows the whistleblower to choose whether or not to provide their identity; access to the Portal is managed in no-log mode in order to prevent the identification of the whistleblower who intends to remain anonymous. In any case, the whistleblower may supplement his/her personal details at a later date through the Portal.
After access, the whistleblower will be guided in filling out a questionnaire that will allow them to provide, in written or oral form, the elements characterizing the report (facts, context, etc.). The whistleblower is also given the right, again through the Portal, to request a face-to-face meeting.
When the report is sent, the Portal will issue the whistleblower with a unique identification code (ticket). This number, known only to the whistleblower, cannot be recovered in any way in case of loss. The ticket will be used by the whistleblower to access, again through the Portal, their report in order to: monitor its progress; insert additional elements to substantiate the report; complete their personal details; submit or answer any in-depth questions. In fact, the Portal allows a virtual conversation to be established between the whistleblower and the recipient, guaranteeing the necessary confidentiality and, at the discretion of the Whistleblower, anonymity.

Who handles the report
The task of receiving reports is entrusted to the Chairman of the Company's Supervisory Body established pursuant to Legislative Decree 231/01.The management of reports is the responsibility of the Supervisory Body in a collegial form. 
The Supervisory Body has its own Operating Regulations which define the procedures for managing reports that may involve one of the members of the Body itself (so-called conflict of interest). In addition, the Whistleblowing Policy regulates situations of conflict of interest in the management of the report by the Supervisory Body.
An acknowledgement of receipt will be sent to the whistleblower within 7 days from the date of submission, through the Portal. Further information will then follow, again through the Portal, at the end of the investigation into the reported event, and in any case no later than 3 months.

Protection and responsibility of the whistleblower
No retaliation or discrimination, direct or indirect, may arise against those who have made a report in good faith. In addition, there are sanctions against those who violate the whistleblower's protection measures.

Sanctions are provided for against the whistleblower, where possible, in the case of reports made with intent or gross negligence or that prove to be false, unfounded, with defamatory content or in any case made for the sole purpose of damaging the Company, the reported or subjects affected by the report. The Company may also take appropriate legal action.

Protection of the reported
The report is not sufficient to initiate any disciplinary proceedings against the reported person. If, as a result of concrete feedback acquired regarding the report, it is decided to proceed with the preliminary activity, the reported person may be contacted and the right to provide any necessary clarification will be guaranteed.

Recommendations
The Portal is intended for use by those who, in good faith and in accordance with ethical principles of integrity, report conduct that may not comply with laws and regulations or with the Company's internal principles and procedures, of which they have become aware. Such reports are also accepted anonymously. The Company will prosecute the authors of reports made in bad faith, with defamatory intent or that do not fall within the correct spirit of collaboration with the company.
The protections provided to the Whistleblower do not apply to disputes, claims or requests related to a personal interest of the Whistleblower that relate exclusively to their individual employment relationships, or inherent to their employment relationships with hierarchically superior figures. Therefore, we invite you NOT to use the Portal with reference to these issues; in general, the Company urges its employees to resolve any labour disputes, where possible, through dialogue, including informal dialogue, with their colleagues and/or with their direct manager.
Likewise, please do not use the Portal for complaints, requests for assistance and other questions of a commercial nature.
Reports must be made in a spirit of responsibility, be of interest to the common good, and fall within the types of non-conformities for which the system has been implemented.
Please refrain from reporting that does not fall under the above cases.

Privacy policy
All reports are strictly confidential. Any personal data contained in the report will be processed in compliance with the rules for the protection of personal data and the GDPR Policy adopted by the Company. For more information, see the "Privacy Policy" section. 

Useful links
Consult the Whistleblowing Policy
Consult the Privacy Policy
Submit a report: https://tecnospa.integrityline.com