Whistleblowing

Whistleblowing

In compliance with the provisions set out by the new Whistleblowing legislation (Legislative Decree No. 24/2023 implementing EU Directive No. 1937/2019), Zero1 S.r.l. provides reporting channels for its employees, collaborators, business partners, suppliers, and other parties who wish to submit detailed reports of unlawful conduct of which they have become aware in the course of their duties and that may seriously threaten the reputation of Zero1 S.r.l.

In light of the aforementioned legal provisions, Zero1 S.r.l. has drawn up an internal procedure dedicated to this function.

The purpose is to enable Zero1 S.r.l. to handle reports within the timeframes established by the applicable legislation, to disclose situations of risk or harm, and thereby contribute to the prevention and mitigation of potential unlawful conduct.

Through appropriate channels and methods that ensure protection and confidentiality for the whistleblower, all stakeholders can contribute to preventing and countering unlawful conduct.

The channels implemented by the Company ensure that neither the person reported nor any third party not expressly designated by the organization as a recipient of the reports or as a party responsible for subsequent investigations can access the report or the identity of the whistleblower.

 

Reporting channels

Anyone who, by virtue of their work duties, becomes directly aware of any anomalies, serious irregularities, or violations may submit a report, even anonymously, through these channels:

By calling our dedicated phone number or requesting a face-to-face meeting.

+39 0423 755853

By regular mail or registered letter with return receipt Addressed to:

Zero1 S.r.l. Sole Shareholder Company Via del Lavoro 15, 31039 – Riese Pio X (TV) with the wording “Whistleblowing Report” written on the envelope.

 

Management

The report will be handled confidentially by the designated office, which is required not to disclose the whistleblower’s identity. Any personal data contained therein will be processed in compliance with the applicable privacy regulations and retained only for the period strictly necessary to manage the report.

 

What to Report

Zero1 S.r.l. strongly encourages the reporting of any improper, dishonest, or potentially illegal activities, as well as behaviors that may cause harm or damage, including reputational harm, to the Company itself. To this end, Zero1 S.r.l. has implemented specific rules and a whistleblowing procedure to provide potential whistleblowers with secure channels that ensure the confidentiality of their identity and of the information contained in the report, as well as their protection from any possible retaliation.

Reports, complaints, and public disclosures may concern information regarding violations of national or European Union laws. The subject of reports may include violations or behaviors, acts, or omissions that are detrimental to the public interest or to the integrity of a public administration or private entity, including:

• Administrative, accounting, civil, or criminal offenses;

• Acts or omissions that harm the financial interests of the European Union or relate to the internal market, of which individuals have become aware in a public or private work context.

The Procedure also takes into consideration, and therefore may include as Reportable, any unlawful conduct relevant to Zero1 S.r.l.’s Policy that does not fall within the offenses specified in the Whistleblowing Decree mentioned above, but rather within the SA8000 standard, in accordance with Procedure 16 – Social Responsibility Requirements.

 

What Not to Report

- Complaints, claims, or requests related to a personal interest of the reporting person or of the individual who has filed a report with the judicial authorities, which concern exclusively their own individual employment or public service relationships, or their working relationships with hierarchically superior figures.

- Reports of violations that are already mandatorily regulated by acts of the European Union or national acts indicated in Part II of the Annex to the Decree, or by national acts implementing the European Union measures listed in Part II of Annex (EU) Directive 2019/1937, even if not expressly mentioned in Part II of the Annex to the Decree.

- Reports of violations concerning national security matters, as well as contracts related to defense or national security aspects, unless such aspects fall within the relevant derived law of the European Union.

 

Protection of the Whistleblower

Reports are handled with the utmost confidentiality, in accordance with the methods set out in the specific Procedure, and the identity of the whistleblower—when voluntarily disclosed—will not be revealed, except as required by law. Any retaliatory or discriminatory act against the whistleblower, whether directly or indirectly related to the report, is strictly prohibited. Disciplinary sanctions are provided for anyone who breaches the measures protecting the whistleblower.

 

Protection of the Reported Person

The reported person cannot be subjected to disciplinary action based solely on the whistleblower’s statements, without objective evidence and without an adequate investigation into the reported facts. Similarly, reports made in bad faith, opportunistically, or found to be unfounded and made with gross negligence may also result in disciplinary or other appropriate legal consequences.