Whistleblowing

F.LLI CANIL S.p.a. encourages and promotes a culture inspired by legality, ethics, transparency and Gender Equality.

To this end, F.LLI CANIL S.p.a. has activated:

  • a web service for sending written reports, accessible at the following link: https://ethicpoint.eu/canil/;
  • a dedicated toll-free number for first assistance to the reporter, for oral reports (tel. 800 985 231);
  • a physical mailbox, for sending written reports. In particular, reports may be forwarded to Audit People S.r.l – Società Benefit PO BOX n. 301 c/o Mail Boxes Etc. via Felice Bellotti 4, 20129 Milan, specifying the company name of F.LLI CANIL S.p.a. in the report;

Through the aforesaid channels, members of their corporate bodies, employees, collaborators but also external parties may report any irregularities of which they have become aware and which could cause prejudice or damage to the Company or third parties.

Along with the aforesaid channels, reports concerning breaches of Gender Equality can be sent to the following channels:

  • email genderequality@canil.com;
  • mail box available by the cafeteria on the ground floor of the Bessica di Loria office. 

All reports will be treated with the utmost discretion and confidentiality in order to protect the person making the report from any risk of being subjected to retaliatory or discriminatory acts in his/her work context.

Furthermore, the personal data acquired will be processed in full compliance with Regulation (EU) 2016/679 and the Privacy Code.


HOW CAN A REPORT BE SUBMITTED?

 A report can be sent:

  • in written form, by accessing the following link: https://ethicpoint.eu/canil/;
  • in written form, by writing to: Audit People S.r.l – Società Benefit PO BOX n. 301 c/o Mail Boxes Etc. via Felice Bellotti 4, 20129 Milano, specifying the company name of F.LLI CANIL S.p.a. in the report;
  • orally, by contacting the following toll-free number: 800 985 231;

For reports on breaches of Gender Equality, besides the aforesaid channels:

  • in writing, sending an email to genderequality@canil.com;
  • in writing, placing a report in the aforementioned mailbox available by the Coffee bar, on the ground floor of the Bessica di Loria offices

It is advisable for the reporting party to provide as much information as possible on the incident (also following the instructions provided by the platform), taking care to describe in detail the facts to be reported.

The reporter may also indicate other persons who may report the incident and attach files or documents to support the report.

WHO CAN MAKE A REPORT?

Legislative Decree 24/2023: In addition to directors and members of the corporate bodies, employees or collaborators of F.LLI CANIL S.p.a. who are or have been witnesses, even indirectly, to an offence or irregularity committed by the relevant company or one of its employees may make a report. This category also includes volunteers, trainees and self-employed workers. 

Reports may also be submitted by external parties (e.g. suppliers), provided that the information was learnt in the context of their own work.

A legal relationship with the Company does not need to be in place at the time of the report. 

UNI PdR 125:2022: whoever acquires knowledge of conduct or situations that breach Gender Equality principles can make a report. This includes employees, collaborators, former employees, candidates not hired and even third parties like suppliers or consultants


WHAT CONDUCT CAN BE REPORTED?

Legislative Decree 24/2023: reports may be submitted in relation to conduct, acts or omissions that harm the public interest or the integrity of the Company. These may include:

  • unlawful conduct pursuant to Legislative Decree 231/2001 or violations of the organisation and management model adopted by the Company;
  • offences falling within the scope of European Union or national legislative acts concerning the following areas: public procurement; financial services, products and markets; prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation and nuclear safety; safety of food and feed and the health and welfare of animals; public health; consumer protection; privacy and personal data protection; and the security of networks and information systems;
  • acts or omissions prejudicial to the financial interests of the European Union;
  • acts or omissions that undermine the functioning of the internal market (e.g. breaches of rules on competition and State aid);
  • acts or conduct intended to circumvent or frustrate the object or purpose of the provisions laid down in EU legislation.

Complaints concerning an interest of a personal nature of the reporter and which relate exclusively to his/her individual employment relationship cannot be reported.

UNI PdR 125:2022: reports considered relevant include, merely as an example, any breach of the Gender Equity Policy or policies connected to it, or any discriminatory behaviour that goes against company guidelines. Moreover, all forms of violence, whether physical or verbal, as described in the company Policy are relevant. Last of all, improvement proposals for existing company situations or processes are considered whistleblowing reports.

WHAT HAPPENS AFTER A REPORT?

Leg. Decree 24/2023: All whistleblowing reports are received by an external company in charge of managing whistleblowing channels (the Whistleblowing Channel Manager), which will send the whistleblower an acknowledgement of receipt within 7 days.

Reports received by the Whistleblowing Channel Manager, unless manifestly irrelevant, will be forwarded to the Supervisory Board, which will carry out an analysis to assess their validity. The whistleblower may be contacted at a later stage, for additions or further information. Once the report has been processed and the necessary investigations have been carried out, the whistleblower will be informed of the outcome by the Whistleblowing Channel Manager.

The report may be dismissed in the event of manifest unfoundedness or irrelevance with respect to the scope of application.

UNI PdR 125:2022: After receiving a report regarding Gender Equity, the manager of the Whistleblowing channels forwards it to the Guiding Committee which also handles reports received by email at the specific address or through the physical mailbox. The Guiding Committee checks the reports and, if breaches or crimes are suspected, promptly notifies the shareholders, corporate bodies, Top Management and employees.

Whistleblowing reports made in order to damage someone or which prove not to be founded can imply disciplinary measures for the whistle-blower. Moreover, the Guiding Committee is obliged to document all reports to guarantee process traceability.

The Guiding Committee for Gender Equity will then contact the whistle-blower within 90 days from receiving the report to update him/her on how the enquiries are progressing. At the end of the investigation, a report will be issued on the result and on the whistle-blower’s contribution.

HOW IS THE CONFIDENTIALITY OF THE REPORTER PROTECTED?

All data relating to the report (identity of the persons involved and the content of the report) are protected by security measures and standards (e.g. encryption tools and other methods to protect against unauthorised access). 

The identity of the whistleblower is only known by the persons in charge of handling the report, who are required to ensure that the confidentiality of the whistleblower and of the other persons mentioned is strictly respected.

CAN THE REPORT BE SENT ANONYMOUSLY?

When completing the report, the reporter may decide not to reveal his or her identity. 
However, whistleblowers are encouraged to prefer to disclose their identity, thus ensuring absolute respect for the confidentiality of the whistleblower and the application of the protections provided for by Legislative Decree 24/2023, which otherwise could not be enforced against an unknown person. 

Leg. Decree 24/2023: This also entails greater effectiveness in the investigations that will subsequently be conducted by the Supervisory Board, which will only be able to investigate anonymous reports if their content is clear, precise, complete and therefore capable of bringing to light certain facts and situations.


MISUSE OF THE CHANNEL (PERSONAL CLAIMS, MANIFESTLY UNFOUNDED OR DEFAMATORY REPORTS)

Complaints concerning an interest of a personal nature of the whistleblower and relating exclusively to his/her individual employment relationship may not be reported. 

The channels may also not be used to make reports of an obviously defamatory and opportunistic nature.


WHAT HAPPENS IF THE REPORT IS CLEARLY UNFOUNDED AND DEFAMATORY?

F.LLI CANIL S.p.a. does not tolerate the incorrect use of the reporting channels provided, or the use of such channels to make reports of an obviously defamatory and opportunistic nature.
Should these elements be found in the report or, in any case, should it emerge that the person making the report was prompted by the intention to damage or unfairly blame other persons, the Company reserves the right to take disciplinary and/or legal action against such persons.
Furthermore, in the event that the whistleblower is found to be responsible for the incorrect use of the channels (e.g. with a first-degree judgement), the protections provided for by Legislative Decree 24/2023 will not be guaranteed.

WHEN TO MAKE AN EXTERNAL REPORT?

An external report is a report addressed to ANAC to a competent external body outside the company.

Leg. Decree 24/2023: A whistleblower may make a report to ANAC when:

  • a whistleblowing channel has not been set up in his own work context or if activated this does not comply with the provisions of Legislative Decree 24/2023;
  • the reporting person has already made an internal report, but this has not been followed up;
  • the reporting person has reasonable grounds to believe that, if he/she were to make an internal report, it would not be effectively followed up, or that it could give rise to a risk of retaliation;
  • the reporting person has reasonable grounds to believe that the breach may constitute an imminent and clear danger to the public interest.

UNI PdR 125:2022: a whistle-blower may make a report to the Equity Manager when:

  • no internal channel related to Gender Equity has been set up; or if that channel does exist it does not meet the requirements set by UNI PdR 125:2022;
  • the whistle blower has already made an internal report regarding Gender Equity, but there has been no follow-up;
  • the whistle-blower feels he/she has sound motives for believing that an internal whistleblowing report would not be seriously considered or could submit him/her to risks;
  • the whistle-blower feels that the breach of Gender Equity could represent an immediate danger to collective interests, especially if it concerns discrimination or violence in the workplace.

Link to the whistleblowing portal – Ethic Point: https://ethicpoint.eu/canil/

Chiudi