Exprivia has always been attentive to the prevention of risks that could compromise the responsible and sustainable management of its business and is convinced that operating in compliance with ethical principles is rewarding for the company’s activities. To this end, it counteracts the occurrence of phenomena deriving from the violation of the regulatory framework that oversees correctness, honesty and loyalty in every relationship, both internal and external, by adopting a commitment to “zero tolerance” towards corruption in any form, reiterated both in the Code of Ethics and in the Organization, Management and Control Model adopted pursuant to Legislative Decree 231/01 since 31/3/2008.

For this reason, also adhering to the indications of the Corporate Governance Code for companies listed on the Italian Stock Exchange, Exprivia has introduced a digital platform that allows all stakeholders to report – through an online portal – hypotheses of illegal conduct or irregularities and violations of company procedures and provisions.

Reports will be processed by the Exprivia Ethics Committee and the Supervisory Body. The Ethics Committee is made up of the Internal Audit, the Head of the Human Resources function, the Head of the Legal function and the RGPC (Head of the Management System for the Prevention of Corruption).

The system allows you to send reports without the obligation to register or declare your personal details. If the Whistleblower chooses to indicate his/her personal details, his/her confidentiality is guaranteed.

All personal data will be processed in accordance with the current legislation on the protection of personal data, meaning EU Regulation 2016/679 (GDPR) as well as any other relevant legislation applicable in Italy, in full compliance with the fundamental rights and freedoms of the subjects involved, with particular regard to the confidentiality of their identity and the security of processing.

LEGISLATION

FAQ

Anyone can send a report to Exprivia SpA or Exprivia Projects Srl (the “Companies”): employees, directors, statutory auditors, shareholders, managers and, in general, all those who operate, in Italy and abroad, on behalf of or for the benefit of the aforementioned companies, who work for them or who have business relations with them through any type of contract or assignment (self-employed workers, collaborators, freelancers, customers, suppliers, partners, consultants, agents, intermediaries, trainees, volunteers, interns, etc.).

  1. Reports must concern, in general, the reasonable and legitimate suspicion or awareness in good faith of unlawful conduct or irregularities in the context of work or collaboration with the Company that may harm the integrity of the Company itself or of the Exprivia Group. They may therefore be attributable to:
  • violation of national or European legislation, including administrative, accounting, civil or criminal offences
  • violations of the Organization, Management and Control Model pursuant to Legislative Decree 231/2001;
  • violations of the Code of Ethics (discrimination, harassment, conflict of interest, …);
  • violations of internal provisions or procedures that can be sanctioned by disciplinary action, including those relating to social responsibility issues (e.g. compliance with work required by law, adequate, safe and healthy workplace, non-discrimination, gender equality, fairness) and the prevention of corruption (e.g. events of active and passive corruption, gifts, donations);
  • in general, facts that may constitute crimes or cause damage (financial or reputational) to the Company or the Exprivia Group.

The following must not be reported and, in any case, will be ignored by the system:

  • facts based on “rumors” or reported “by hearsay”;
  • disputes, claims or requests related to a personal interest of the reporting person that relate exclusively to his or her individual employment relationships.

The following internal channels can be used:

For written reports

  • web portal: Whistleblowing
  • sending ordinary mail to the address Via Adriano Olivetti n.11—70056 – Molfetta (BA), specifying the recipient company (Exprivia SpA or Exprivia Projects Srl), for the attention of the Supervisory Body or the Ethics Committee

For oral reports

  • Call by phone at +39 080 5362998
  • request for a direct meeting with the whistleblowing managers, via the telephone number +39 080 5362998

The web portal is the reporting channel that offers the greatest guarantees of confidentiality and protection of the identity of the whistleblower and all data related to the report, including the data of the whistleblower.

The whistleblower may use the external reporting channels set up by ANAC on its institutional portal only when one of the following conditions is met:

  1. the whistleblower has already made an internal report and the same has not been followed up;
  2. the whistleblower has reasonable grounds to believe that, if he or she made an internal report, it would not be followed up effectively or that the same report could lead to the risk of retaliation;
  3. the whistleblower has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest.

On a residual basis and limited to the occurrence of the conditions indicated below, reporting is allowed through public disclosure through the press or electronic means or in any case through means of dissemination capable of reaching a large number of people. The whistleblower who makes a public disclosure benefits from the protection provided for by the Decree if, at the time of public disclosure, one of the following conditions is met:

  1. the whistleblower has previously made an internal and external report or has made an external report directly and has not been responded to within the established deadlines;
  2. the whistleblower has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest;
  3. The whistleblower has reasonable grounds to believe that the external report may involve the risk of retaliation or may not be effectively followed up due to the specific circumstances of the specific case, such as those in which evidence may be concealed or destroyed or in which there is a well-founded fear that the person who received the report may be colluding with the offender or involved in the violation itself.

The report must contain useful elements to allow the bodies responsible for the analysis and processing of the report itself to proceed with the appropriate checks to verify its validity. The report must therefore contain the following elements:

  • a clear and complete description of the facts reported;
  • the circumstances of time and place in which they were committed;
  • the personal details or other elements (such as the qualification and the service in which he carries out the activity) that allow the identification of the person(s) who carried out the reported facts;
  • the indication of any other subjects who can report on the facts subject to reporting;
  • the indication of any documents or other evidence that may confirm the validity of these facts;
  • any other information that can provide useful feedback on the existence of the reported facts.

Yes, it is possible to submit anonymous reports. The Company will take into consideration such reports if the elements indicated are detailed in order to bring out facts and situations on which it is possible to make the necessary findings.

The management of reports through internal channels is entrusted to a Whistleblowing Office which is composed as follows:

    1. the Ethics Committee, made up of the Internal Auditor and the heads of the Human Resources and Legal functions and the RGPC (Head of the Management System for the Prevention of Corruption), which, upon receipt of the reports, will analyse, verify and process them, in any case informing the Supervisory Body (SB); if the reports relate to offences referred to in Legislative Decree 231/01, it will submit them to the management of the SB
    2. by the Supervisory Body, which will analyse, verify and process reports falling within the offences referred to in Legislative Decree 231/01 and which, if it considers the reports not within its competence, will submit them to the management of the Ethics Committee. Even where the report is the responsibility of the Supervisory Board, the latter will inform the Ethics Committee, with the exception only of those member(s) who may be in conflict of interest with the report, of the report received and managed by it.

In the event that you believe that one of the members of the assessment team is involved to some extent in the report or you consider it necessary or even only appropriate that one of these members should be excluded from the management of the report, it is possible, using the web portal, to highlight this circumstance within the portal itself and exclude certain subjects from submission.

Yes, within seven days of receipt of the report, the managers of the report will issue the whistleblower with information of receipt and acceptance of the report. This notice will be forwarded to the address indicated by the whistleblower in the report, if any.

In addition, the handlers of the report will provide feedback to the report within three months from the date of the acknowledgement of receipt or, in the absence of such notice, within three months from the expiry of the seven-day period from the submission of the report.

Certainly. The author of the report sent through the Whistleblowing web portal will be able to have continuous access to check the evolution of his report using the unique code provided by the web portal when opening the report.

The protection system prescribed by Legislative Decree no. No. 24/2023 provides for a set of protections granted to the whistleblower and the so-called facilitators, i.e. the subjects who are part of the same work context as the whistleblower and who have facilitated the submission of the report, as well as to the person reported or involved in the report. Provided that the report has been made in accordance with the procedures and requirements provided for by Legislative Decree no. no. 24/2023 and set out in the Procedure, the main guarantees are:

  1. the protection of the confidentiality of the whistleblower, the facilitator, the person involved and the persons mentioned in the report;
  2. protection against any retaliatory measures adopted by the Company against the whistleblower and facilitators;
  3. exclusion from civil, criminal, administrative or disciplinary liability of the whistleblower with respect to the disclosure and dissemination of certain information