Whistleblowing

Monari Federzoni S.p.A. has always been attentive to preventing risks that could compromise the responsible and sustainable management of its business.

 

For this reason, the company has adopted an Organizational, Management, and Control Model pursuant to Legislative Decree no. 231/2001 ("Model 231"), which includes a Code of Ethics and a Whistleblowing procedure.

Monari Federzoni S.p.A. has also entrusted a Supervisory Body ("OdV")—an autonomous and independent body—with the task of overseeing compliance with the provisions of Model 231, verifying their effectiveness, and evaluating the need for updates.

In this context, Law no. 179/2017, titled "Provisions for the protection of whistleblowers reporting crimes or irregularities of which they have become aware in the context of public or private employment," introduced the tool known as "whistleblowing."

The Italian legislator, with Law no. 2022/127, delegated the government to implement Directive (EU) 2019/1937 on the protection of persons in the public and private sectors who report violations of Union law, with the possibility of extending it to other acts/sectors by the member states. On March 10, 2023, the Council of Ministers approved Legislative Decree no. 24, which adjusts to the EU Directive.

This tool, which protects the integrity of the company, allows reporting—also confidentially—to the Supervisory Body or the designated Report Manager of any behaviors learned through one's role within the company that may constitute violations of Model 231 or illegal conduct relevant under Legislative Decree no. 231/2001, as well as violations of EU regulations in a wide range of sectors explicitly indicated in the annex to Directive (EU) 2019/1937 (including public procurement, financial services, product and transport safety, environment, food, public health, privacy, network security, competition).

 

To this end, Monari Federzoni S.p.A. has established a whistleblowing procedure that guarantees two confidential reporting channels to the Supervisory Body or the designated Report Manager for potential non-compliance with Model 231, ethical principles, applicable laws and regulations, or other sectors indicated by law.

This procedure is accessible only when the whistleblower—who has become aware of the issue through their role—is acting in good faith and the report is based on precise and consistent factual elements.

Monari Federzoni S.p.A. encourages reporting any irregularities in good faith but does not tolerate false or harassing statements, mere suspicions or rumors, personal grievances, or claims. In such cases, disciplinary actions will be taken against those who abuse the whistleblowing procedure.

It is also noted that the company may consider and analyze anonymous reports after verifying:

 

  • The seriousness of the issue raised;
  • Its credibility;
  • The likelihood that the issue will be confirmed by reliable sources.

Monari Federzoni S.p.A. has adopted (i) a web-based reporting platform; (ii) a dedicated telephone line for reports; (iii) a dedicated email address; and (iv) a reporting box located at the company's registered office. All channels ensure compliance with privacy protection regulations for the whistleblower's identity, the reported person, any third parties/witnesses mentioned, and the facts reported in the submission.

Depending on the area of concern for which the whistleblowing report is to be submitted, the specific form titled "REPORTING FORM" must be used (i) for violations of Model 231, the Code of Ethics, or illegal conduct relevant under Legislative Decree no. 231/2001; (ii) for administrative, accounting, civil, or criminal offenses as well as other violations of EU regulations in a wide range of sectors explicitly indicated in the annex to Directive (EU) 2019/1937 (including public procurement, financial services, product and transport safety, environment, food, public health, privacy, netw

ork security, competition).

The aforementioned form can be accessed by clicking on the following link: https://segnalazioni.monarifederzoni.com/#/

 

Alternatively, a report can be submitted by calling: 059/801770 and pressing “1” for Monari Federzoni S.p.A.