1) Who can submit a report?
Anyone can submit a report to Italtel; employees in Italy and abroad, as well as all those working for or on behalf of Italtel Group or having business relationships through any kind of contract or assignment (customers, suppliers, partners, consultants, agents, interns, …)
2) What kind of report can I submit?
The reports should concern the reasonable and legitimate suspicion or in good faith awareness of unlawful conduct in the working activity that could adversely affect the integrity of Italtel Group. They should, therefore, be referable to:
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- violations of the Code of Conduct (discrimination, harassment, conflict of interest, …);
- violations of the Organization, Management, and Control Model according to Italian Legislative Decree 231/2001;
- in general, events that may cause offenses or produce damage (financial or reputational) to Italtel Group;
- violations of internal provisions or procedures that can be sanctioned disciplinarily.
The following must not be reported and, in any case, they will be ignored by the system:
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- facts based on “rumors” or “by hearsay”;
- personal complaints.
3) Which channels can I use to submit a report?
You can use the following channels:
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- Whistleblowing web portal
through the corporate intranet or, from outside, through the corporate web site www.italtel.com
- e-mail addresses
comitato_etico@italtel.com
odv@italtel.com
- telephone number
+39 02 4388 2421
- Ordinary mail address
Comitato Etico Italtel / Organismo di Vigilanza Italtel / Compliance Officer Italtel
Via Caldera 21
20153 Milano
The WB web portal is the primary channel adopted by Italtel as it offers the greatest guarantees of confidentiality and protection for your identity and all the data included in the report.
4) What are the contents of a report?
The report must contain elements that are useful for allowing the bodies in charge of the analysis and processing of the report to proceed with the appropriate checks to verify their validity. The report must, therefore, contain the description of the facts (including places and dates), persons engaged, any names of other persons who may have information on the facts reported; it can also contain attachments (documents, photos, audio, and video recordings).
5) Can I submit a report anonymously?
Yes, you can submit reports anonymously. Italtel will consider these reports as long as the reported elements are detailed to bring out facts and situations on which it is possible to make the necessary checks.
6) Who will take charge and process my report?
Reports are received, analyzed, verified and processed by the Italtel Ethics Committee consisting of the Compliance Officer, the head of the Human Resources department and the head of the Legal department. If you believe that one of the members of the Ethics Committee is involved in some way in your report or if you believe necessary or even only appropriate that one of these members should be excluded from the processing of your report, you can decide, using the web portal, to inhibit automatically the sending of all information and notifications to such member.
7) Can I follow the progress status of my report?
Certainly. You can have continuous feedback on the evolution of your report using the unique code provided by the web portal when you submitted your report.