Whistleblowing

The new Whistleblowing procedure to report any unlawful conduct that you may have become aware of in the workplace is available on our website, in accordance with the Italian Legislative Decree No. 24/2023, transposing the European Whistleblowing Directive (2019/1937). Urbani & HTL has established reporting channels that adopt all the necessary measures to ensure the confidentiality of the whistleblower in order to avoid retaliation.

Pursuant to the Italian Legislative Decree No. 24/2023, Urbani & HTL has implemented its own internal channel to report any behaviour, act or omission that may harm the public interest or the integrity of the public administration or of private entities, while ensuring the confidentiality of the parties protected by the law.

Violations of national or EU regulatory provisions that harm the public interest or the integrity of the public administration or of private entities that have come to light in the context of employment and/or commercial relationships with Urbani & HTL and that consist of:
· administrative, accounting, civil or criminal offences;
· unlawful conduct relevant under the Italian Legislative Decree No. 231/2001, or violations of the organization and management policy required by the same;
· offences falling within the scope of European Union or national legislation relating to the following sectors: public procurement; financial services, products and markets and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; protection of privacy and protection of personal data and security of networks and information systems;
· acts or omissions that may damage the financial interests of the Union;
· acts or omissions concerning the internal market;
· acts or behaviour that defeat the object or purpose of European Union legislation.

· Internal channel made available by Urbani & HTL;
· External channel (ANAC, The Italian Anticorruption Authority);
· Public disclosure (via the press, electronic means or means of dissemination capable of reaching a large number of people) only when the conditions set out in Article 15 of the Italian Legislative Decree No. 24/2023 have been met;
· Report to the judicial or accounting authority.
The reporting party will be required to use the internal channel, established according to the highest security standards available to ensure the protection of their rights, except in the cases expressly provided for by Article 6, according to which the reporting party may contact ANAC directly.
Anonymous reports are permitted by the legislation, but their use is not recommended as they hinder both the dialogue with the reporting party and the conduct of investigations.

The whistleblower will be required to provide all useful information to allow the competent offices to proceed with the necessary and appropriate checks to verify the validity of the events reported. To this end, the report should preferably contain the following elements:
· personal details of the reporting party, stating the position held or functions performed within the company, or other connection with it;
· a clear and complete description of the events being reported;
· if known, the circumstances of time and place in which they were committed;
· if known, personal details or other information (such as qualification and service in which the activity was carried out) enabling the identification of the person who committed the act or acts being reported;
· information on any other parties who may provide a description of the events being reported;
· information on any documents that could confirm the validity of such events;
· any other information that may effectively confirm the events being reported.

The reporting party will be notified of receipt of the report within 7 days of its receipt.

· Discussions will be held with the reporting party and, if necessary, such person will be asked to provide additional information and/or useful clarifications in order to handle the report with the greatest effectiveness;
· All reports received will be diligently followed up, carrying out the relevant investigation;
· The final outcome will be communicated to the reporting party within three months of notification of receipt of the report.

· The identity of the reporting party will not be disclosed to persons other than parties authorized to receive or follow up on reports;
· Protection will concern not only the name of the reporting party, but also all reported information which may reveal the identity of the reporting party, including indirectly;
· The report will not be subject to the right of access to administrative documents and to the general right of civic access;
· Confidentiality protection will include the identity of any persons involved (reported persons) and of any persons mentioned in the report as well as of facilitators, persons in the same work context and work colleagues of the reporting party in compliance with the same guarantees provided for the reporting party.

· At the time of filing a report or making a complaint with the judicial or accounting authority or at the time of public disclosure, the whistleblower or reporting party had reasonable grounds to believe that the information on the reported, publicly disclosed or claimed violations was true and fell within the objective scope of the report (Article 1, para. 1, Italian Legislative Decree No. 24/23);
· The report or public disclosure was made according to the provisions of Chapter II of the Italian Legislative Decree No. 24/23, i.e. using the channels and under the conditions specified therein.

Without prejudice to specific limitations of liability provided for by Article 20 of the Italian Legislative Decree No. 24/23, if the reporting party is found criminally liable, even after a first-instance judgment, for defamation, slander, or similar offenses committed by filing the report with judicial or accounting authorities or is found civilly liable for the same conduct in cases of wilful misconduct or gross negligence, confidentiality protections will not apply and the reporting party or whistleblower will face disciplinary penalties.

Any personal data relating to the receipt and management of reports will be processed by Urbani & HTL in the capacity of data controller in compliance with European and national principles on the protection of personal data, providing appropriate information to the reporting parties and to the persons involved in the reports, and adopting appropriate measures to protect the rights and freedoms of the data subjects.

Furthermore, the rights of access, rectification and erasure referred to in Articles 15 to 22 of Regulation (EU) 2016/679 will be guaranteed, except for the limitations specified in Article 2 of the Italian Legislative Decree No. 196 of 30 June 2003.

The reports and related documentation will be retained for the time necessary to process the report itself and, in any case, no longer than for 5 years from the notification date of the final outcome of the whistleblowing procedure, in compliance with the confidentiality obligations laid down in European and national legislation on the protection of personal data.

Reports, whether written or verbal, will be filed through a dedicated platform which guarantees the necessary levels of confidentiality and protection of the reporting party and content thereof. An interview with the managing entity may be requested on the platform in order to file the report in person.