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
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
Access to this website by visitors is subject to the following conditions:
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.
Persons working in the company's work environment, namely:
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:
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).
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:
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.
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:
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.
The reporting Channel Manager performs the following activities:
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.
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