Whistleblowing_

WHISTLEBLOWING AND REPORTING POLICY
 

MICOS S.p.A., hereafter referred to as MICOS, has implemented an anonymous reporting system for behaviours that do not comply with the MOG pursuant to Legislative Decree No. 231/2001, to the Code of Ethics, or to applicable laws and regulations. The system aims to prevent potential unlawful or irregular conduct and to promote a culture of ethics and legality among employees, clients, suppliers, and all stakeholders, fostering a transparent, participatory, and inclusive organisational environment.

In compliance with Legislative Decree No. 24/2023, the Company has adopted the “My Governance” Reporting and Complaints System for the receipt, analysis, and management of reports concerning MICOS, whether submitted by external parties or internal personnel, while ensuring a simple and secure process to protect those who report unlawful conduct in the workplace.

WHAT CAN BE REPORTED?

Through the “My Governance” system, anyone can confidentially report unlawful conduct that they genuinely believe, based on reasonable and factual grounds, has occurred and of which they have become aware.

Reports may relate to suspected offences, including but not limited to the examples listed below:

• Violations of MICOS’s 231 Organisational Model and related implementing procedures, the Company’s Anti-Corruption Policy, the Code of Ethics, internal company regulations, or any conduct likely to cause harm or prejudice—whether actual or reputational—to MICOS;
• Administrative, accounting, civil, or criminal offences;
• Unlawful conduct relevant under Legislative Decree No. 231 of 8 June 2001;
• Offences falling within the scope of European Union legislation and related national implementing provisions;
• Acts or behaviours that undermine the purpose or objectives of EU legislation;
• Professional conduct contrary to principles of respect for individuals (e.g., discrimination, harassment, mobbing, etc.);
• Breaches of rules protecting client interests (e.g., charging commissions without informing the client, improper arbitration, etc.);
• Unauthorized disclosure of confidential information, theft, or data breaches;
• Violations of human rights, fundamental freedoms, or the health and safety of people or the environment, identified in activities carried out by MICOS, a client, or a supplier with a commercial relationship with MICOS;
• Serious breaches of supplier policies;
• Situations conflicting with or violating the principles of social responsibility as defined in the SA8000 Standard.

Reports concerning grievances, personal requests, or, more generally, matters that are not relevant for the purposes described above may not be taken into consideration. Reports must be made in good faith, be detailed, and based on clear and consistent factual evidence, in order to ensure the effectiveness of the reporting system provided.

REPORTS’ HANDLING

Reports are addressed to the Company’s Supervisory Body and/or the relevant internal authorities according to the area of competence. The Supervisory Body manages reports related to violations or attempted circumvention of the 231 Organisational Model and/or its implementing procedures, as well as breaches of the Code of Ethics that have, or could have, relevance under Legislative Decree No. 231/2001.

If, following verification, a report is found to be well-founded, MICOS will act in relation to the nature of the violation, including:

1.a) Communicating the outcome of the investigation to the Company’s management and relevant departments, so that any additional measures or actions necessary to protect the Company may be taken;

2.b) Informing the Chief Executive Officer of the confirmed violation, so that appropriate disciplinary action may be carried out;

3.c) Reporting the matter to the competent authorities.

WHO CAN MAKE A REPORT?

ANYONE – employees, suppliers, clients, or others – may submit a report. MICOS guarantees the absolute confidentiality of the reporter’s identity, the content of the report, and the identity of the individual being reported, regardless of whether the report is submitted anonymously or not. Secure protocols and encryption tools are used to protect personal data and the information provided. The reporter’s identity is never disclosed without their consent, except where required by law.

MICOS strictly prohibits (and will sanction, to the extent permitted) any form of retaliation or discriminatory behaviour, direct or indirect, against a reporter arising from their report. This includes omissions, attempted or threatened actions, as well as actions directed towards third parties connected to the reporter, such as relatives, colleagues, or legal entities owned by or employing the reporter, operating in a work context related to MICOS.

WHISTLEBLOWING THROUGH EXTERNAL CHANNELS AND PUBLIC DISCLOSURE

The two supplementary reporting methods (External reporting channel to ANAC and Public disclosure) may be used only when there is no response through the internal reporting system. For operational procedures and guidance, reference should be made to the relevant provisions of the applicable legislation (Legislative Decree No. 24/2023 – Whistleblowing).

PERSONAL DATA PROCESSING

As part of the reporting management process, personal data are processed in compliance with applicable legislation (EU Regulation 2016/679 and Legislative Decree 196/2003, as amended by Legislative Decree 101/2018). The MICOS Privacy Policy can be consulted at the following link: https://www.micosspa.it/privacy-policy/.

Similarly, once a report has been submitted, the data will be processed in accordance with the ZUCCHETTI Group Privacy Policy, available here: https://www.mygovernance.it/privacy-policy/.

HOW TO REPORT AN ISSUE

Follow the instructions provided here:

READ – WHISTLEBLOWING INSTRUCTIONS (IT) [mygovernance.it]

Then access the following link to submit your report:
https://areariservata.mygovernance.it/#!/WB/MICOS