Itelyum has an internal system for reporting acts or facts that may constitute crimes or illegal conduct. “Whistleblowing”, in the regulatory meaning of the term, is a written or oral report concerning behaviour, risks, offences or irregularities, committed or attempted, to the detriment of the public interest or the integrity of the company, which you have become aware of through your employment or collaboration with the company in question.

In line with the provisions of Legislative Decree 24/2023 and of the EU Directive on Whistleblowing, people who can report these non-compliances are those who have or have had professional relations with one or more companies of the Group, such as:

• employees and self-employed workers;
• professional collaborators;
• workers or collaborators who supply goods or services or carry out work for third parties;
• freelancers and consultants;
• volunteers and trainees (paid and unpaid);
• shareholders (natural persons);
• persons with administrative, control, supervisory or representative functions.

The Reporting Management Body is the person/structure responsible for ensuring the proper conduct of the process. The whistleblower may also request, via the digital platform, a meeting in person to make the report. The platform complies with the provisions of the Italian Anti-Corruption Authority (ANAC), EU Regulation 679/2016 (GDPR) and the national Legislative Decree No. 24 of 10 March 2023: “Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law and laying down provisions on the protection of persons who report breaches of national law”.

Document related to the reporting process:

• Privacy Policy according to the GDPR (General Data Protection Regulation – EU Regulation
  2016/679).

Other reports

The same platform, created to meet a legislative obligation, can also be used by all interested, internal and external, national and transnational parties, for reports of a different nature, typically related to acts of discrimination, unethical behaviour, improper and/or non-compliant with the Code of Ethics and other company policies, or not in line with the principles of legality and fairness that ITELYUM promotes in the conduct of its business. The tool allows you to choose the language in which you wish to proceed: Italian or English.

Both types of reports described above can be made anonymously with guarantee of confidentiality, anonymity and protection; your personal data will be encrypted so that it is impossible to trace your identity,which will only be known to the report manager in charge. With him/her/them you can interact for further information or to attach documents. Documents may be textual or audiovisual. In the case of reports made via audio recording, the platform will introduce voice distortion mechanisms to ensure that the reporter cannot be recognised.

Documents related to the reporting process:

• Privacy Policy pursuant to the GDPR (General Data Protection Regulation – EU Regulation 2016/679).