Whistleblowing refers to the voluntary disclosure by an individual, known as the “whistleblower,” of a wrongdoing or irregularity that they have witnessed within the company while performing their duties.
The following individuals are eligible to report:
Employees (including those with occasional work, part-time, intermittent, or fixed-term contracts), apprentices, volunteers, and interns, even if unpaid;
Self-employed workers, freelancers, and consultants;
Shareholders (natural persons);
Workers and collaborators employed by public or private entities providing goods or services or carrying out work on behalf of third parties (Suppliers);
Individuals holding administrative, managerial, supervisory, monitoring, or representation roles, including de facto roles (e.g., Board members, Directors, Supervisory Board members, and Statutory Auditors).
Additionally, the protections outlined in Legislative Decree No. 24/2023 against discriminatory practices also apply to:
Facilitators: Individuals assisting the whistleblower in the reporting process;
Individuals in the same working context: Those connected by a network of relationships formed within the whistleblower’s or complainant’s working environment (e.g., colleagues, former colleagues, or collaborators);
Colleagues: Individuals working in the same environment as the whistleblower or complainant and maintaining regular contact with them;
Entities owned by or employing the whistleblower: Entities operating in the same working context as the aforementioned individuals.
Reports may concern the following:
Conduct and/or practices not in line with the company’s codes of conduct and regulations;
Threats, pressures, offers, or promises of money or other benefits;
The commission or potential commission of crimes referenced in Legislative Decree 231/01, or behavior violating the Company’s Code of Ethics or Model 231;
Acts or omissions that harm the financial interests of the European Union, such as fraud, corruption, or other illegal activities related to EU expenditures;
Acts or omissions affecting the internal market, compromising the free movement of goods, people, services, and capital;
Acts or behaviors undermining the purpose or objectives of EU provisions;
Violations falling within the scope of EU or national acts concerning:
Public procurement;
Financial services, products, and markets, as well as prevention of money laundering and terrorist financing;
Product safety and compliance;
Transport safety;
Environmental protection;
Radiation protection and nuclear safety;
Food and feed safety, animal health, and welfare;
Public health;
Consumer protection;
Data privacy and protection;
Network and information systems security.
Complaints, claims, or requests related to personal interests of the whistleblower or concerning their employment relationship or hierarchical superiors should not be reported through the whistleblowing channel.
Reports can be submitted through the following channels:
Online via My Whistleblowing Add-On in My Governance:
Access the URL: https://areariservata.mygovernance.it/#!/WB/digimax
Register by entering your name, surname, and a personal email address (please avoid using corporate email as per the Data Protection Authority's guidelines).
Log in with your credentials and click “CREATE REPORT.” The platform will notify the whistleblower of the report's status through specific notifications.
Direct Meeting with the Channel Manager:
A meeting can be scheduled with the Channel Manager in a designated private area within the company, following a request submitted using the Meeting Request Form.
ANAC Channel (as per the official website):
This channel should only be used in cases where:
No internal reporting channel is available, even if mandatory;
An internal report was already submitted but no action was taken;
The whistleblower has reasonable grounds to believe that an internal report would not be effectively addressed or may result in retaliation;
There is a clear and imminent danger to public interest.
Before proceeding with the report, please carefully read the Whistleblowing Procedure Document.
The report should include:
A clear and complete description of the facts being reported;
The time and place in which the events occurred;
Identifiable information about the individuals involved (e.g., position, service location);
Any supporting documents;
The names of other individuals who can provide information about the reported events;
Any other relevant information that can substantiate the report;
The whistleblower’s contact information (preferably email) for communication regarding the report.
The Channel Manager has been designated as the Head of the Human Resources Department – Administration Area. Any requests for information or clarification regarding the reporting channels can be directed to: Gestoresegnalazioni@digimax.it.
Upon receiving the report, the Channel Manager will handle it in four phases:
Registration and Storage;
Eligibility Assessment and Preliminary Review;
Investigation and Communication of Outcome to the Whistleblower;
Archiving or Forwarding to Competent Authorities for Disciplinary Action.
Confidentiality: The whistleblower’s identity and any other information contained in the report, including documentation, are kept confidential.
Prohibition of Discrimination: Whistleblowers are protected from any form of discrimination (e.g., dismissal, suspension, demotion, termination of a fixed-term contract, negative performance reviews, or references).
These protections extend to facilitators and others connected to the whistleblower (e.g., coworkers).
Criminal, civil, administrative, or disciplinary liability is excluded if the whistleblower reveals information covered by secrecy (official, professional, scientific, or industrial secrets) or related to copyright or personal data protection, provided the report is made through the proper channels and there are reasonable grounds to believe that the information is necessary to expose the violation.
Liability is also excluded if the whistleblower discloses information about violations that may harm the reputation of the person involved, provided the report is made through the proper channels and with reasonable grounds for the disclosure.
Liability is excluded if the whistleblower obtains information about violations through lawful access or prior consent, or by actions not constituting criminal conduct.
Liability is not excluded for actions unrelated to the report or unnecessary for exposing the violation.
€10,000 to €50,000: For retaliatory acts or for obstructing, attempting to obstruct, or breaching confidentiality obligations.
€10,000 to €50,000: For failing to establish reporting channels, adopting non-compliant procedures, or neglecting to verify and analyze received reports.
€500 to €2,500: For loss of protections, unless the whistleblower is convicted (even in the first instance) of defamation, slander, or similar crimes committed through the report to judicial or accounting authorities.
Related Documents: