Whistleblowing
The procedure is part of the internal control tools adopted by the Company General Noli S.p.A in order to prevent corruption, guarantee honesty and transparency when conducting business and in the activities carried out, and protect its standing and reputation.
The reports must be made in good faith and may also be anonymous. To protect the “reporter” as much as possible, the necessary security measures have been put in nplace: the identity of whoever submits a report and its content will be kept confidential through secure protocols and encryption tools which allow the protection of personal data and information, including the information disclosed in any attachments.
The corporate body responsible for the management of the reports is the Whistleblowing System Manager. The reports are managed in a transparent manner through a predefined procedure. The entire process guarantees the reporters protection from pressure and discrimination, be it direct or indirect, from the individuals responsible for the verification of the reports. The identity of the reporter shall never be revealed without consent from the reporter, with the exception of cases in which the verifications conducted following the reports do not fall within the
specific case of criminal, administrative or tribunal investigations, or they give rise to a disciplinary procedure based solely on the complaint received, for which knowledge of the identity of the author of the report is absolutely essential to the defence of the accused.
Therefore, Whistleblowing represents an important pillar of the security system of General Noli S.p.A.
Thanks to secure communication protocols and encryption systems, the portal:
- Protects the identity of the reporter and does not disclose it without the explicit
consent of the reporter; - Protects the identity of the accused;
- Maintains the confidentiality of the information in all contexts following the report;
- Permits the computerised management of reports to company departments
responsible for receiving and verifying them.
Section 1: Italian Legislative Decree 231/2001 and Supervisory Committee
Pursuant to the Italian Legislative Decree no. 231 on the administrative liability of companies, General Noli S.p.A has implemented an Organisation, Management and Control Model which ensures accuracy and transparency when conducting business and aims to prevent crimes committed in the interest of or to the advantage of the company.
According to Italian Legislative Decree no. 231 of 8 June 2001, companies and all organisations in general may be called to respond in criminal proceedings, and therefore incur sanctions, to any crimes committed in their interest or benefit by the directors, employees and other parties who operate in the name or on behalf of the organisation or company. In particular, the Decree considers crimes in relationships with the Public Administration, corporate crimes, crimes linked to safety in the workplace and the environment, organised crime, terrorism, cyber crime, crimes against industry and commerce, crimes against individuals etc. To minimise the risk of these crimes being committed, each company is obligated to implement an “Organisation and Management Model”, that is, a set of regulations and procedures, including the adoption of a Code of Ethics and set of Anti-Corruption Guidelines, the establishment of a Supervisory Board and implementation of a control and sanctions system. The adoption and effective implementation of the Model and the appointment of the Supervisory Board allow the organisation to benefit from the hold harmless clause in the event of crimes.
The General Noli “Model 231” is a dynamic and shared document. It is dynamic because it is sensitive to all regulatory and organisational changes. It is shared because its creation involves all of the company population, both in the phase prior to drafting, via the risk assessment, and in the implementation phase, through training and information.
Supervisory Board of General Noli S.P.A
The Supervisory Board of the Company (hereafter referred to as SB) is a collective body, provided with powers of initiative and control, whose members, selected by the Board of Directors, must possess the traits of autonomy, independence, professionalism, continuity of service and integrity. The SB is tasked with duties of supervising compliance with the provisions of the Model, the effectiveness of the Model and the opportunity to update it, in addition to operative duties linked to the application of the Model.
The Board of the Company General Noli S.p.A. is composed of three members, who are all external:
Chairman: Dr. Michele Gucci
Member: Rag. Roberto Tofani
Member: Dr. Luca Porciani
Monitoring and updating the Model
All areas at risk of crimes being committed pursuant to Italian Legislative Decree 231 and the rules of conduct in the Model are the product of an analysis of corporate documentation and meetings with personnel, in order to adapt the Model to the characteristics of the Company.
The General Noli Model undergoes continuous assessment to evaluate its efficiency and guarantee it is updated according to internal changes (in the organisational structure, in business activities…) and external changes (legislative changes, best practices…).
Training and information
The training of personnel is an essential element for the efficient implementation of the Model. Therefore, a training plan has been devised which includes both classroom sessions and e-learning modules with diversified content based on the addressees and which uses concrete examples. For the purposes of evaluating the quality of teaching, upon completion of the courses, tests will be distributed on the subjects of the lesson.
Reporting Violation of the Organisational and Management Model
Reports of violation of Model 231 can be sent electronically to: organismodivigilanza@pec.generalnoli.it or via post through the internal channel activated by the Company and indicated in the “Whistleblowing Procedure”.
Section 2: Code of Ethics
General Noli S.p.A in carrying out its activities complies with the laws and regulations in force in all of the countries where it does business. The Company acts in observance of the principles of liberty, dignity of the human person and respect for diversity, rejecting any discrimination based on gender, race, language, personal and social conditions, and religious and political beliefs. The Company seeks to build its own growth by strengthening an image that is true to the values of fairness and loyalty. It believes therefore that the respect for ethical rules and transparency in the conduct of business is a necessary condition, as well as a competitive advantage, in order to pursue and achieve its objectives. To this end, General Noli S.p.A. promotes the creation of an environment featuring a strong sense of ethical integrity, in the firm belief that such an aspect is crucial for the effectiveness of policies and control systems, affecting conduct that might otherwise escape most sophisticated supervision systems.
Therefore, the Company has adopted a document, called “Code of Ethics” which governs the rights, duties and responsibilities that General Noli S.p.A. assumes while performing its corporate activities towards all stakeholders that deal with it directly or indirectly and that are capable of influencing its activity or are influenced by it.
Section 3: Whistleblowing
General Noli S.p.A has created a digital space to offer employees and all citizens the possibility of reporting any or alleged unlawfulness about which they have come to know. General Noli S.p.A has always been particularly attentive to the prevention of risks which could compromise the responsible and sustainable management of its business. For this reason, the Reporting Procedure – Whistleblowing has been created. It is a web tool available for all who wish to report situations which could cause damage or detriment to the company, like fraud, generic risks or a potentially dangerous situation.
The procedure is part of the internal control tools adopted by the Company General Noli S.p.A in order to prevent corruption, guarantee honesty and transparency when conducting business and in the activities carried out, and protect its standing and reputation.
The reports must be made in good faith and may also be anonymous. To protect the “reporter” as much as possible, the necessary security measures have been put in place: the identity of whoever submits a report and its content will be kept confidential through secure protocols and encryption tools which allow the protection of personal data and information, including the information disclosed in any attachments.
The corporate body responsible for the management of the reports is the Whistleblowing System Manager. The reports are managed in a transparent manner through a predefined procedure. The entire process guarantees the reporters protection from pressure and discrimination, be it direct or indirect, from the individuals responsible for the verification of the reports. The identity of the reporter shall never be revealed without consent from the reporter, with the exception of cases in which the verifications conducted following the reports do not fall within the specific case of criminal, administrative or tribunal investigations, or they give rise to a disciplinary procedure based solely on the complaint received, for which knowledge of the identity of the author of the report is absolutely essential to the defence of the accused.
Therefore, Whistleblowing represents an important pillar of the security system of General Noli S.p.A.
Thanks to secure communication protocols and encryption systems, the portal:
- Protects the identity of the reporter and does not disclose it without the explicit consent of the reporter;
- Protects the identity of the accused;
- Maintains the confidentiality of the information in all contexts following the report;
- Permits the computerised management of reports to company departments responsible for receiving and verifying them.
