To make a report, including anonymously, Aquafil has adopted an independent IT platform, developed and operated by a third party, in accordance with Legislative Decree No. 24 of March 10, 2023.
This platform is the first-line tool for sending and managing reports, as it can most effectively:
- protect the confidentiality of the reporter, the reported person and other persons involved
- promptly tackle issues reported in compliance with the internal corporate procedure (“Whistleblowing”).
Who can make a report
The following people may make a report:
- Aquafil Group employees and members of its administrative and supervisory bodies;
- Third parties, i.e. those persons who have, have had, or intend to have a working or business relationship with Aquafil.
Contents of reports
Reports must be made in good faith and be substantiated with accurate information, thereby making it easier to verify and manage them without needing to involve the reporter. At the same time, reports must not address situations of an exclusively personal nature. Significant reports are considered to be those that relate to:
- administrative, accounting, civil or criminal offences;
- violation of the provisions of the Ethics Code or the Code of Conduct;
- illegal conduct relating to the commission of the crimes set out in Legislative Decree No. 231/2001;
- offences falling within the scope of European Union or national acts, e.g. in the areas of public procurement, services, food safety, animal health and well-being, public health, consumer protection, etc.;
- acts or omission or fraud that damage the financial interests of the European Union;
- acts or omissions relating to the domestic market, including EU budget fraud or corrupt activities;
- acts or conduct that impinge on the object or purpose of the provisions set out in EU Acts.
Management of reports
Reports are addressed to a Management Body external to the organisation, which is formally mandated and staffed specifically to manage reports. Where the report may even potentially have Legislative Decree No. 231/01 implications, the Management Body shall promptly inform the entire Supervisory Board and the Internal Committee.
If, following preliminary checks, the report is found to have some basis, the receiving Management Body begins the appropriate verification. This involves Aquafil’s Internal Committee and other relevant corporate functions in ascertaining the veracity of the facts described in the report.
If the report is found to be true, Aquafil will take any measures deemed appropriate along with any action required to protect the company.
As part of the reporting process, personal data are processed in compliance with the relevant legislation in force (EU Regulation 679/2016 and Legislative Decree No. 196/2003) and retained for the period of time strictly necessary to manage the report. As per the regulations, this may not exceed five years. Personal data that is irrelevant to management of the case shall be deleted without undue delay.
The Whistleblowing procedure as described in whistleblower protection and reporting channels also applies to Group subsidiaries, subject to local laws.
Reports relating to foreign subsidiaries are forwarded to the relevant bodies of that company for investigation.
Protections
Aquafil has taken measures to ensure that the reporter’s identity remains confidential in order to prevent any form of retaliation or discrimination against the reporter.
During the investigation and verification of any possible non-compliance, individuals referred to in reports may be involved in or notified of the report, but under no circumstances will proceedings be initiated by disclosing the reporter without the consent of the latter.
As part of disciplinary proceedings, the reporter’s identity may not be disclosed, where the allegation of the disciplinary charge is based on separate and additional investigations to the report, even if consequent to it; If the charge is based, in whole or in part, on the report and knowledge of the reporter’s identity is indispensable for the defence of the accused, the report may be used for the purposes of disciplinary proceedings.
Responsibilities of the reporting person
It is the responsibility of the reporting person to make reports in good faith and in accordance with the spirit of the applicable legislation: reports that are manifestly false or entirely unfounded, opportunistic, and/or made for the sole purpose of harming the reported person or persons otherwise affected by the report will not be considered. In the event that a report made with malice or gross negligence turns out to be unfounded, the reporter shall be liable for sanction, as per Aquafil’s internal disciplinary system and in line with local laws.
Reporting methods
To make a report, the reporter must log in to the platform https://aquafil.integrityline.com/.
The Reporter has the option to submit their Report either in writing, by completing the designated fields, or verbally, by sending a voice message. The report can also be submitted completely anonymously.
Upon completing the report, the Reporter is assigned a unique code (ticket) and asked to set a personal password. These two elements allow the Reporter to access the site to track the status of the report and receive any requests for additional information from the Managing Body.
The Reporter can set the site language by choosing from those used in the Group’s main production facilities: Chinese, Croatian, English, Italian, and Slovenian.