Clivet S.p.A.

Sede Legale / Legal Site:

Via Camp Lonc, 25
32032 Z.I. Villapaiera,
Feltre (BL) Italy

info@clivet.it


Cap. Soc. Euro 20.000.000,00 i.v.
Reg. Imp. Belluno, P.IVA e C.F n. 00708410253
REA n. 66577, SDI: EUC8LBT

LEGAL NOTICES

Access to this website by visitors is subject to the following conditions:

  • The information, logos, graphics, images, trademarks and all else published and/or reproduced in this site are the property of Clivet S.p.A.
  • Production of the contents of this site is permissible only with written authorization from Clivet S.p.A. (marketing@clivet.com)
  • It is therefore prohibited to modify, copy, reproduce, distribute, transmit or distribute the contents of this site without authorization.
Whistleblowing

Clivet S.p.A., aware of the importance of activating suitable reporting channels in order to protect the integrity of the Company and ensure compliance with the principals of legality, accuracy and transparency, and also with respect to third parties, when carrying out business activities, has taken steps to implement specific corporate reporting channels in accordance with Italian Legislative Decree no. 24/2023, implementing EU Directive 2019/1937.

With this Circular Letter, Clivet S.p.A. intends to encourage the most extensive distribution to all Recipients of all relevant information on the channels, procedures and requirements for making internal and external reports.

WHO CAN MAKE A REPORT

Persons working in the company's work environment, namely:

  • employees;
  • self-employed workers and collaborators working at the Company’s premises;
  • freelancers and consultants working at the Company’s premises;
  • volunteers and trainees, paid and unpaid, working at the Company’s premises;
  • shareholders and persons with administration, management, control, supervision or representation roles, even if such roles are performed on a de facto basis at the Company’s premises, even when the legal relationship has not yet begun, if the information on the violations was obtained during the selection process or other pre-contractual stages or during the trial period or after termination of the legal relationship if the information on the violations was obtained in the course of the relationship.

WHAT TYPES OF BEHAVIOUR CAN BE REPORTED

Relevant Reports are reports concerning conduct, acts or omissions affecting the public interest or the integrity of the Company of which the whistleblower has become aware during his or her work and which consist of:

  • relevant unlawful conduct pursuant to Italian Legislative Decree no. 231/2001 and violations under Model 231, such as corrupt conduct towards the Public Administration, Occupational Health and Safety breaches, and infringements of Environmental regulations. These reports can only be made through the internal reporting channels;
  • offences falling within the scope of European Union acts concerning the following areas: public procurement; services, products and financial markets and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; food and feed safety and animal health and welfare; public health; consumer protection; privacy and personal data protection and security of networks and information systems;
  • acts or omissions that affect the financial interests of the European Union;
  • acts or omissions relating to the national market, including violations of EU competition and State aid standards, as well as corporate taxation regulations.
  • acts or omissions that thwart the object or purpose of the provisions of the aforementioned European Union acts.

Excluded from the scope of Relevant Reports are objections, claims or requests linked to a personal grievance of the whistleblower that relate exclusively to his or her individual employment relationships with hierarchically senior figures.
Also excluded are information that is clearly unfounded, information that is already fully in the public domain, and information obtained based only on indiscretions or rumours that are not very reliable (gossip).

CHARACTERISTICS OF THE REPORT

In order to ensure that the report is processed correctly, it must be as detailed as possible so that the relevant person can receive and handle the reports and verify the wrongdoing. Namely, the following should always be indicated:

  • the circumstances of time and place in which the wrongdoing reported occurred;
  • description of the wrongdoing;
  • personal information or other elements allowing identification of the individual to whom the wrongdoing reported can be attributed;
  • any enclosed documents;
  • any individuals potentially aware of the wrongdoing.
  • Remember that, in order to keep his or her identity confidential and benefit from the protections provided in the event of any retaliation, the whistleblower must indicate that he or she is reporting under this regulation (Whistleblowing Law).

Anonymous Relevant Reports are also processed, as applicable, by the Channel Manager. If the whistleblower, anonymously, is subsequently identified, the same protection measures apply in case of retaliation.

INTERNAL REPORTING CHANNELS

So that written or oral Relevant Reports can be submitted, the Company, having consulted the Unitary Trade Union Representative, activates and keeps open the following reporting channels: 

  1. this postal address: Clivet S.p.A., Via Camp Lonc. n. 25, 32032 Feltre (BL) - Z.I. Villapaiera (FAO the Channel Manager); to ensure confidentiality, the communication must be sent by the whistleblower in a sealed envelope clearly stating “Whistleblowing Report”; 
  2. voice messaging system on the whistlelink.com Platform developed by Whistleblowing Solutions AB; 
  3. This IT channel: whistlelink.com Platform developed by Whistleblowing Solutions AB (https://clivet.whistlelink.com/).

If the whistleblower requests a face-to-face meeting, it is arranged by the Channel Manager within a reasonable time and in a manner that maintains confidentiality. 
Clivet S.p.A., in full compliance with the Whistleblowing Decree, guarantees that the aforementioned channels ensure that the identity of the whistleblower, of the person involved and of any person mentioned in the report, as well as the content of the report and of the relevant documentation, are kept confidential.
The reporting channel is managed by an Ethics Committee formed by: Ms. Alice De Cet (CFO and HR Director), Ms. Viki Vittadello (Integrated Quality System & Certifications Manager) and Mr. Alfredo Pivato (Senior Legal Specialist) (The “Channel Manager”).
To ensure that the report is processed correctly, internal or external individuals may be involved who do not have a conflict of interest and who will, in any case, be bound by the confidentiality obligations set out in the regulation.

REPORT HANDLING PROCEDURES

The reporting Channel Manager performs the following activities:

  • issues the whistleblower with an acknowledgement of receipt for the report within seven days from the date of receipt; 
  • liaises with the whistleblower and may request additional information, if deemed necessary;
  • diligently follows up the reports received by involving the individuals in charge of handling the report, e.g. the Supervisory Body for reports under Model 231; provides feedback to the whistleblower within three months of the date of the acknowledgement of receipt or, in the absence of such acknowledgement, within three months of the expiry of the seven-day term from when the report was submitted. This feedback may also be of an interlocutory nature if the investigation has not yet been completed. Once the investigation has been completed, the whistleblower must nevertheless be informed of the outcome.

THE EXTERNAL REPORTING CHANNEL (ANAC)

The whistleblower may make an external report using the channels specifically set up by ANAC (National Anti-Corruption Authority) if, at the time of the report, one of these conditions is met: the company’s internal reporting channel is not active or, if it is activated, is not compliant pursuant to Italian Legislative Decree no. 24/2023; the whistleblower has already made an internal report and the report has not been followed up; the whistleblower has reasonable grounds for believing that, if he/she were to make an internal report, it would not be effectively followed up or that the report might entail the risk of retaliation; the whistleblower has reasonable grounds for believing that the violation might constitute an imminent or obvious danger to the public interest. Any retaliation experienced may be reported to the same channel. See https://www.anticorruzione.it/-/whistleblowing

The data will be processed in accordance with GDPR no. 679/2016 and Italian Legislative Decree no. 24/2023.

Please see Privacy Whistleblowing.