Whistleblowing

Anyone can submit a report to Italtel; employees in Italy or abroad, as well as everyone who works for or on behalf of Italtel Group or have business relationships through any kind of contract or assignment (collaborators, consultants, agents, intermediaries, interns,…)

The reports should concern information, including well-founded suspicions, regarding violations committed in the working activity that could adversely affect the integrity of Italtel Group. They should be referred to:

• violations of the Organization, Management and Control Model pursuant to Italian Legislative Decree 231/2001;
• violations of the Code of Conduct (discrimination, harassment, conflict of interest, …);
• administrative, accounting, civil or penal offences;
• violations of internal provisions or procedures that can be sanctioned disciplinarily;
• in general, events that may cause offenses or produce damage (financial or reputational) to Italtel Group.

The following must not be reported and, in any case, they will be ignored by the system:

• disputes, claims or requests related to a personal interest concerning exclusively individual employment relationships;
• facts based on “rumors” or “by hearsay”;

You can use the following channels to send an internal report:

• Whistleblowing web portal

through the corporate intranet or, from outside, through the corporate web site (https://www.italtel.com/it/about/whistleblowing/)

• 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 web portal is the primary channel adopted by Italtel.

You can also send an external report to the ANAC (National Anti-Corruption Authority) in the event that you have already sent an internal report without receiving a reply or in the event that you have well-founded reasons to believe that the report will not be effectively processed or the report could lead to a real risk of retaliation (https://www.anticorruzione.it/-/whistleblowing#p0).

The report must contain elements that are useful for allowing the bodies in charge for the analysis and processing of the report to proceed with the appropriate checks to verify its 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).

Yes, you can submit anonymous reports. Italtel will take these reports into consideration if the elements indicated are detailed so that it is possible to carry out the necessary checks.

Reports are received, analyzed, verified and processed by the Italtel Ethics Committee formed by 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 transmission of all information and notifications to such member.

Certainly. You can have continuous feedback on the evolution of your report using the unique code provided to you by the web portal when you submitted your report.