WHISTLEBLOWING

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

F.A.Q.
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 in the report;
orally, by contacting the following toll-free number: 800 985 231;
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?

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.

WHAT CONDUCT CAN BE REPORTED?

Illegal conduct relevant under Legislative Decree 231/2001 or violations of the organisation and management model adopted may be reported.
Complaints concerning an interest of a personal nature of the reporter and which relate exclusively to his/her individual employment relationship cannot be reported.

WHAT HAPPENS AFTER A REPORT?

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.

HOW IS THE CONFIDENTIALITY OF THE WHISTLEBLOWER 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.
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.
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.

Link di accesso al portale whistleblowing – Ethic Point: https://ethicpoint.eu/canil/