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Whistleblowing

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1. INTRODUCTION
Legislative Decree 24/2023, which entered into force on March 30, 2023, and became effective for the Organization as of December 17, 2023, implemented Directive (EU) 2019/1937 of the European Parliament and of the Council of October 23, 2019, into our legal system. This directive concerns the protection of persons who report violations of Union law and contains provisions regarding the protection of persons who report violations of national regulatory provisions.
Numerous innovations have been introduced, affecting various aspects such as: the subject matter of violations, the scope of reporting parties, the activation and methods of using reporting channels, the involvement of ANAC (National Anti-Corruption Authority), the extension of protection measures to individuals or entities supporting the whistleblower, etc.
These Instructions have been drafted by the Organization to provide clear information to anyone intending to make a report pursuant to the aforementioned Decree regarding available channels, procedures, and requirements for internal and external reporting. These Instructions are made known to potential whistleblowers through publication on the Organization’s website.
2. WHO CAN FILE A REPORT AND BENEFIT FROM THE PROTECTIONS?
The reporting person, known as the whistleblower, is the natural person who reports or publicly discloses information on violations acquired within their work context. More specifically, this refers to:

  • Employees of the Organization, regardless of contract type (e.g., permanent, part-time, intermittent, fixed-term, agency workers, apprentices, occasional work, etc.);
  • Self-employed workers, collaborators, suppliers of goods and/or services, or those carrying out works for third parties who perform their work for the Organization;
  • Freelancers and consultants providing services to the Organization (e.g., commercial agents, lawyers, engineers, etc.);
  • Volunteers and trainees, whether paid or unpaid, working for the Organization;
  • Shareholders and persons with functions of administration, management, control, supervision, or representation (including de facto roles) at the Organization.
Notably, a report can be made not only during the employment relationship but also during a probationary period, prior to the establishment of the relationship (e.g., during pre-contractual/selection phases), or after the termination of the relationship, provided the information was acquired during said relationship.
3. WHO ARE THE OTHER PARTIES COVERED BY THE PROTECTIONS?
For the first time, the Legislator has extended protections to other parties who may be involved in the matter for various reasons. These include:
  • The Facilitator: A natural person in the same work context who assists the whistleblower in the reporting process (e.g., an office colleague);
  • Persons in the same work context: Individuals linked to the whistleblower by a network of relationships arising from their common work environment, including those with a stable emotional bond (e.g., cohabitants) or kinship within the fourth degree;
  • Work colleagues: Those currently working in the same context who have a regular and ongoing relationship with the whistleblower (not merely sporadic or exceptional);
  • Entities owned (exclusively or by majority share) by the whistleblower, or for which they work, and entities operating in the same work context.
4. WHAT IS A REPORT?
A report is a written or oral communication regarding information on violations, submitted through the reporting channels detailed below.
5. WHAT CAN BE REPORTED AND WHAT IS EXCLUDED?
In accordance with ANAC Guidelines (Resolution no. 311/2023), any information learned in the whistleblower's work context regarding violations of EU law or national implementing regulations—including acts, behaviors, omissions, or violations that could likely be committed based on concrete elements—may be reported. This includes well-founded suspicions and conduct intended to conceal violations.
Specifically, the following may be reported:
  • Offenses falling within the scope of EU or national acts concerning: public procurement; financial services, products, and markets; 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; protection of privacy and personal data; and network and information systems security.
  • Acts or omissions affecting the financial interests of the Union or concerning the internal market.
  • Acts or behaviors that defeat the object or purpose of Union provisions.
Excluded from the scope of Whistleblowing:
  • Disputes, claims, or requests linked to a personal interest relating exclusively to individual employment relationships or relationships with hierarchical superiors;
  • Violations already mandatorily regulated by other sources providing specific reporting procedures;
  • Violations regarding national security or defense procurement (unless covered by relevant EU secondary law).
Information that is clearly unfounded, already in the public domain, or acquired solely through unreliable rumors is also excluded. The motives behind the report are irrelevant to its processing or the protection of the whistleblower.
6. WHAT IS THE MINIMUM CONTENT OF A REPORT?
A report must be as detailed as possible. Specifically:
  • Identify the whistleblower;
  • Circumstances of time and place of the event;
  • A description of the facts;
  • Identification (where possible) of the subject responsible for the reported facts. It is advisable to attach supporting documents and indicate other persons potentially aware of the facts. The Organization provides a specific Whistleblowing form as a guide.
7. CAN REPORTS BE ANONYMOUS?
Anonymous reports (where the whistleblower’s identity is unknown) fall outside the scope of Whistleblowing regulations and will be treated by the Organization as ordinary reports, though documentation will still be registered and stored.
8. HOW TO FILE A REPORT (INTERNAL CHANNEL)
The Organization provides an internal channel ensuring confidentiality.
  • Email: Use the encrypted mailbox givas@segnalazioniwb.it.
  • Subject Line: Must state: "Segnalazione Whistleblowing effettuata e da trattare ai sensi del D. Lgs. 24/2023".
  • Direct Meeting: Can be requested via the same email address and will be scheduled within a reasonable timeframe.
  • Privacy Tip: It is recommended not to use company email, company phones, or company networks to file the report. It is also advised to file reports outside of working hours.
9. WHO MANAGES THE INTERNAL CHANNEL?
The channel is managed by XIFRAM S.R.L., based in Padua (Italy), Viale della Navigazione Interna 51.
10. WRONG RECIPIENT
Any person receiving a whistleblowing report who is not authorized to manage it must forward it to the designated manager within 7 days and simultaneously notify the whistleblower of the transfer.
11. POST-REPORT PROCEDURE
The manager will send an acknowledgment of receipt within 7 days. After an initial assessment of admissibility, an investigation begins. A final feedback regarding measures taken or planned will be provided to the whistleblower within 3 months of the acknowledgment.
12. EXTERNAL REPORTING (ANAC)
Whistleblowers may use the external channel provided by ANAC if:
  • The internal channel is not mandatory, not active, or non-compliant;
  • An internal report was made but not followed up within the deadlines;
  • There are well-founded reasons to believe an internal report would not be effectively followed up or could lead to retaliation;
  • The violation constitutes an imminent or manifest danger to the public interest.ANAC Links: Information | Reporting Platform
13. PUBLIC DISCLOSURE
Public disclosure means making information about violations public through the press, electronic media, or social networks capable of reaching a large audience.
14. PROTECTIONS FOR PUBLIC DISCLOSURE AND JUDICIAL REPORTS
Public disclosure is protected only if previous internal/external reports went unanswered, or if there is an imminent/manifest danger to public interest, or a risk of retaliation/ineffective follow-up at the external level. Individuals may also report directly to Judicial Authorities while maintaining protections.
15. PROTECTIONS AND SUPPORT MEASURES
Protections include:
  • Confidentiality of identity for the whistleblower, facilitator, and any person involved;
  • Protection against retaliation (e.g., dismissal, demotion, salary reduction, harassment, discrimination, negative references, etc.);
  • Exemption from liability for revealing certain categories of information under specific conditions.Support measures (free information and assistance) are available via Third Sector entities listed by ANAC.
16. PERSONAL DATA PROCESSING
The Organization will process data in accordance with the privacy policy available on the company website. Data subjects may request a copy of this policy at any time.