Whistleblowing

THE WHISTLEBLOWING

Studio Pirola Pennuto Zei & Associati’s Whistleblowing Portal is available to anyone who wishes to make a bona fide report of illegal conducts or violations of the Code of Ethics, the Code of Professional Conduct, the Organizational, Management and Control Model pursuant to legislative decree 231/2001,  the Firm’s internal procedures or external rules applicable to the Firm. Reports must be made on the basis of precise and consistent factual evidence and in such a way as to protect the Firm’s integrity.

HOW ARE REPORTS SUBMITTED?

The Portal may be accessed in no-log mode to protect the identity of a whistleblower who wishes to remain anonymous.

After access, the whistleblower will be guided in the completion of a questionnaire including open-ended and/or closed-ended questions to gather the key facts and information (including when the reported event occurred, the amounts involved etc.).

After completing the questionnaire, the Portal will ask the whistleblower whether he/she wishes to disclose his/her identity (although he/she may do so at a later time, again through the Portal).

When the report is submitted, the Portal will issue an identification code (ticket ID), which the whistleblower is the only one to know and which may not be recovered if lost. The whistleblower may use his/her ticket ID to access the report through the Portal in order to monitor its status, add further elements, disclose his/her identify, reply to any queries. The Portal enables the whistleblower and the recipient of the report to enter into a chat, again in anonymous form, if the whistleblower so wishes.

WHO HANDLES WHISTLEBLOWER REPORTS?

Whistleblower reports are handled by the Supervisory Body (“Organismo di Vigilanza”) of Studio Pirola Pennuto Zei & Associati.

WHISTLEBLOWER’S PROTECTION AND LIABILITY

No direct or indirect retaliation or discrimination shall be tolerated against a bona fide whistleblower and penalties shall be imposed on anyone violating whistleblower protection rules.

However, if a whistleblower submitted a fraudulent report, a report containing false, unfounded or defamatory information or a report solely designed to harm the Firm, the accused or anyone else affected by the report, he/she shall be liable to penalties, insofar as possible. The Firm may also take appropriate action in court.

PROTECTION OF THE ACCUSED PERSON

No disciplinary action against the accused shall be taken solely upon receiving a whistleblower report. If, however, the evidence obtained thereafter should warrant further investigation, the accused shall be contacted and be given the chance to explain and clarify.

RECOMMENDATION FOR THE USE OF THE PORTAL

The Whistleblowing Portal is meant for use by anyone who, in good faith and according to ethical principles of integrity, wish to report conducts potentially non-compliant with laws and regulations or with the Firm’s principles or internal procedures, which have come to their knowledge. Reports may be anonymous. The Firm shall take appropriate action against anyone who submits defamatory reports, or reports that are in bad faith or do not reflect a spirit of cooperation.

As a rule, the Firm encourages its employees and other staff to resolve any disputes, insofar as possible, through dialog with their colleagues and/or their direct supervisor. Reports must be made responsibly and for the greater good, and shall cover the cases of non-compliance for which the system has been designed. You should refrain from filing reports for reasons other than those mentioned above.

Before filing a report, please read carefully the Firm’s “Whistleblowing policy”.

DATA PROTECTION

Any personal and sensitive data contained in the report, including the identity of the whistleblower or that of other persons, shall be processed in accordance with the rules on personal data protection and with the GDPR Policy implemented by the Firm.

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Whistleblowing Policy

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