“WHISTLEBLOWING PROCEDURE FOR RECEIVING AND HANDLING REPORTS under Legislative Decree No. 24 of 10 March 2023

Premises

Since its establishment, Osteria dell’Orsa SAS (hereinafter, the “Company”) has been committed to creating and maintaining the necessary conditions so that the relations established with all its Employees, Collaborators, Consultants, Shareholders, Suppliers, and Partners always take place in a corporate context of transparency, integrity, and responsibility.
This is the way Osteria dell’Orsa SAS has always conducted its business.

With a view to continuous improvement and in line with the current evolution of the applicable regulations, Osteria dell’Orsa SAS has decided to give a strong signal of respect for the principles mentioned above by strengthening its organisational structures and formalising a company procedure for receiving and managing internal reports, including by adopting a new Procedure for receiving and managing internal reports (“Whistleblowing Protocol”), by Legislative Decree No. 24 of 10 March 2023.

Who can report – Protected persons

Anyone may use the internal reporting channels to communicate possible violations of the law or alleged unlawful conduct of which they have become aware as a result of their relationship with the Company. The persons protected by the legislation against possible retaliation or discriminatory conduct are employees, former employees, trainees, collaborators, consultants, volunteers, trainees, shareholders, persons with administrative, management, control, supervisory or representative functions at the Company, as well as the facilitators and colleagues of the reporter who have a habitual and current relationship with the same. 
How to report

The Company has set up internal reporting channels, managed by an independent external company. 

The channels are:

1) in writing

By sending a letter by ordinary mail (plain and/or registered letter) to the address of the Manager: Noverim S.r.l. Società Benefit, Piazza Degli Affari n. 3, Milan 20123, taking care to indicate on the envelope: “personal confidentiality – Whistleblowing report” and in the text of the letter to indicate the name of the Company.

2) orally, using a direct meeting with the Manager or his delegate specially trained in the matter and appointed for the purpose, and also by privacy regulations. The meeting shall be held within 20 working days of the request, to be sent to whistleblowing@noverim.it. The Manager shall document oral reports, subject to the written consent of the person making the report, either using a recording on a device suitable for storage and listening or using a verbatim transcript. In the case of a transcript, the reporting person must verify, rectify or confirm the transcript’s content by signing it.

The report must be as detailed as possible.
In particular, the following essential elements must be apparent from the report for it to be admissible:

  • (optional) the identifying data of the reporting person (name, surname, place and date of birth) as well as an address (e-mail and telephone number) to which subsequent updates can be sent 
  • (mandatory) the circumstances of time and place in which the reported fact occurred;
  • (obligatory) description of the facts that are the subject of the report with details of the circumstantial information
  • (obligatory) manner of learning of the facts that are the subject of the report 
  • (mandatory) details of the reported person or other elements enabling him/her to be identified.  

It is advisable to attach documents proving that the reported facts are well-founded and indicating other potentially aware persons.

What to report

The subject of the report may be any conduct or facts which, in the reporter’s opinion, constitute or are potentially capable of constituting civil, criminal, administrative or accounting offences and are detrimental to a public or private interest.
This channel can be used to report violations, i.e. conduct, acts or omissions, which damage the integrity of the Company or the public interest, relating – by way of example but not limited to – to

  • violations of laws and regulations (national and European)
  • acts of corruption
  • harassment in the workplace;
  • corporate fraud;
  • human rights; 
  • conduct that causes damage or harm, even if only in terms of image, to the Company.

The report may not concern

  • disputes, claims or requests linked to an interest of a personal nature of the reporting person that relates exclusively to their individual work relations or inherent to their work relations with hierarchically superior figures
  • unsubstantiated information, information acquired only based on indiscretions or rumours that are scarcely reliable (so-called “corridor rumours”)
  • information that is already totally in the public domain.

How reports are handled

An acknowledgement of receipt of the report will be given within 7 days of receipt, and feedback will be provided within3 months of this acknowledgement on the action taken or intended to be taken on the report. 
In any case, the Reporting Manager may interface with the reporter if they deem it necessary to investigate the matter further or initiate a dialogue to obtain clarifications or documents.
The reporting channels may always request a meeting with the Reporting Manager.
Guarantee of confidentiality and safeguards

The reporter, the facilitator, and the persons involved in the report are guaranteed absolute confidentiality. 
No form of personal or professional retaliation is allowed or tolerated because of the report made. If you believe you have suffered retaliation due to your report, you may notify the National Anti-Corruption Authority (ANAC).
Any processing of personal data is carried out in compliance with the data protection legislation. See Annex Privacy Policy. 
Please note that anyone who abuses the protections afforded by this Protocol, by reporting facts or acts that are manifestly unfounded or opportunistic, for the sole purpose of harming the whistleblower or other persons, will be held liable in disciplinary and any other competent forum.

In the case of ordinary reports made to one’s Manager and/or hierarchical superior, the protections provided for by the Whistleblowing Decree are not guaranteed unless the Whistleblower specifies or shows a willingness to benefit from them.

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For further details on the whistleblowing procedure, please refer to the Protocol published on the company intranet and posted on the company notice boards of all the Company’s offices. In any case, you can always request a copy of the Protocol by sending an email to whistleblowing@noverim.it. 

11 December 2023

Osteria dell’Orsa Company