Whistleblowing

In compliance with the provisions of Legislative Decree 24/2023 implementing EU Directive 2019/1937, through the Orbyta Group's Whistleblowing Channel it will be possible to report conduct, acts or omissions that harm the public interest or integrity of one of the Orbyta Group companies.

Questions and answers:

1. Who can send the report?

They can make a report:

employees, self-employed workers, holders of a collaborative relationship and trainees, including unpaid trainees, who perform their work at one of the Orbyta Group companies;
freelancers, consultants and collaborators in any capacity who perform their work at one of the Orbyta Group companies;
in general, anyone who comes into contact, for any reason, with one of the Orbyta Group companies.

2. What to report?

Reports must relate to facts of which the reporter has knowledge and must be made promptly with respect to knowledge of the facts so that timely action can be taken.

In particular, the following may be subject to reporting:

  • unlawful or suspicious conduct, administrative, accounting, civil or criminal wrongdoing;
  • Irregularities in business activities;
  • acts or facts that may constitute a violation of the rules, internal and external, governing the activities of the Orbyta Group or that violate the principles and rules of conduct contained in the Code of Ethics;
  • offenses within the scope of European Union or national acts relating to the following areas: public procurement; financial services, products, and markets and prevention of money laundering and terrorist financing; product safety and compliance; transportation safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; privacy and data protection; and network and information system security;
  • Acts or omissions that harm the financial interests of the European Union;
  • Acts or omissions concerning the internal market;
  • Acts or conduct that frustrate the object or purpose of the provisions set forth in the acts of the European Union.

3. What cannot be reported?

The following may not be reported: disputes, claims, or requests related to interests of a personal nature that pertain exclusively to the employment relationship or inherent in the relationship with hierarchically subordinate figures; communications or complaints related to activities of a commercial or public service nature.

Should the whistleblower make false or defamatory reports - without prejudice to the criminal and civil liability of the whistleblower - the whistleblower may be subject to a disciplinary sanction of €500 to €2,500.

4. How is the confidentiality of the reporter guaranteed and who handles the report?

The Orbyta Group guarantees absolute confidentiality of the reporter's identity and the content of the report, with secure protocols and encryption tools. The identity of the whistleblower is never disclosed without the whistleblower's consent, except in cases provided for by the applicable regulations.

Whistleblowing is handled by a special Whistleblowing Committee composed of individuals who-in accordance with the principles of impartiality, confidentiality, and data protection-are endowed with autonomy and independence.