{"id":6513,"date":"2025-04-03T13:18:04","date_gmt":"2025-04-03T12:18:04","guid":{"rendered":"https:\/\/www.s3kgroup.it\/?page_id=6513"},"modified":"2025-05-13T09:08:22","modified_gmt":"2025-05-13T09:08:22","slug":"whistleblowing","status":"publish","type":"page","link":"https:\/\/www.s3kgroup.it\/en\/whistleblowing\/","title":{"rendered":"Whistleblowing"},"content":{"rendered":"\t\t
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Home<\/a><\/span><\/span><\/p>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t

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whistleblowing<\/h1>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
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Generalities<\/p>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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\u201cWhistleblowing\u201d (hereinafter referred to as \u201cReport\u201d) means any report, coming from all the subjects indicated in the continuation of the document, concerning conduct (of any nature, even merely omissive) referable to Personnel and\/or non-compliant Third Parties\/in violation of laws and regulations, the Code of Ethics and the 231 Organizational Model of S3K S.p.A. (hereinafter also Company).<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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Purpose<\/p>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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The procedure is intended to regulate the manner of making and handling reports, sent or forwarded by any of the individuals concerned, including anonymously, concerning alleged irregularities or wrongdoing of which they have become aware.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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More in detail, the procedure, on the one hand, describes and regulates the process of reporting alleged irregularities or offenses, providing the reporter with clear operational indications about the subject, contents, recipients and methods of transmission of reports, as well as regarding the forms of protection arranged by the Company in accordance with regulatory provisions; on the other hand, that of regulating the methods of ascertaining the validity and substantiation of reports in order to take appropriate corrective and disciplinary action, if necessary.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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Recipients are Top Management, members of the Corporate Bodies and the Supervisory Board, Employees, Partners, Customers, Suppliers, Consultants, Collaborators and Shareholders in possession of information regarding conduct concerning behavior (of any nature, even merely omissive) referable to Personnel and\/or Third Parties that does not comply\/in violation of laws and regulations, the Code of Ethics and the 231 Organizational Model of the Company:<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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This procedure, which is available on the institutional website and the corporate intranet, applies to S3K S.p.A., which guarantees its correct and constant application, as well as its maximum dissemination internally and externally through the institutional sext, while respecting the obligations of confidentiality and the prerogatives of autonomy and independence.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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Definitions<\/p>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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Within this Procedure, the terms below have the following meanings:<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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  1. Reports: any information, even if anonymous, concerning (i) violations or suspected\/presumed violations referred to in Article 2 paragraph 1 letter a of Legislative Decree 24\/2023 and\/or (ii) behaviors or practices that do not comply with the provisions of the Code of Ethics, the Organization and Management Model adopted pursuant to Legislative Decree no. 231 of 2001, the Environmental and Workplace Safety Management System, the Procedures inherent to the management and security of information systems, the Procedures of the data protection and data governance system and the like.<\/li>
  2. Whistleblower: the person making the Report whether employee (including top management), collaborator, member of the corporate bodies, supplier, partner, shareholder;<\/li>
  3. Supervisory Board (\u201cSB\u201d): the body appointed by the Company’s Board of Directors pursuant to Legislative Decree No. 231 of 2001;
    Internal \u201cWhistleblowing\u201d Channel: the internal body responsible for the application of this procedure and the timely transmission of the violation to the Supervisory Board where such a report is relevant under Legislative Decree No. 231\/01.<\/li><\/ol>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
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    Subject and Contents of the Report<\/p>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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    The following conduct is subject to reporting where it becomes known on occasion and\/or cause or otherwise within the scope of the employment\/collaboration or business relationship:<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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    1. Violations or suspected violations relevant pursuant to and for the purposes of Legislative Decree No. 24 of 2023 (Administrative, accounting, civil or criminal offenses; Illicit conduct relevant pursuant to Legislative Decree No. 231; Offenses falling within the scope of European Union acts relating to the following areas: public procurement; services, products and financial markets and prevention of money laundering and financing of terrorism; 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 security of information networks and systems; Acts or omissions relating to the internal market (by way of example: Competition and state aid violations); Acts or conduct that frustrate the object or purpose of the provisions of Union acts);<\/li>
    2. Potential irregularities in the area of market abuse pursuant to EU Regulation 596\/2014;
      Violations of the provisions dictated in function of the prevention of money laundering and financing of terrorism;<\/li>
    3. Behaviors or practices that do not comply with the provisions of the Company’s Code of Ethics, , the Organization and Management Model adopted by the Company, as well as the current internal procedural framework referred to therein, if any.<\/li><\/ol>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
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      Whistleblowing does not concern grievances of a personal nature of the whistleblower or claims\/complaints that fall under the discipline of the labor relationship or relations with the hierarchical superior or colleagues, for which reference should be made to the Human Resources Department, which will handle them in accordance with internal procedures and labor relations regulations<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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      The Report may also be received anonymously. In any case, however, Reports must be circumstantiated and based on precise and concordant elements, relate to verifiable facts, and contain all the elements useful to carry out the checks and verifications necessary to assess their merits.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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      Therefore, it is important that the reporter:<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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