WHISTLEBLOWING

In order to encourage and facilitate the reporting of misconduct and thus reduce the risks of irregularities, IFA CONSULTING SCF Srl has adopted an internal procedure regulating the internal reporting system (Whistleblowing), as required by Legislative Decree No. 24/2023.


PERSONS WHO MAY SUBMIT A REPORT:

Following the provisions of Legislative Decree No. 24/2023, the range of individuals who may submit a Whistleblowing report has been expanded to include:

  • all employees of the company;

  • self-employed workers and individuals with a collaboration agreement, workers or collaborators of suppliers, freelancers and consultants providing services to the company;

  • volunteers and interns (both paid and unpaid);

  • shareholders and individuals with administrative, management, control, supervisory or representative functions;

  • job candidates;

  • probationary workers;

  • former employees.

In accordance with external regulations, IFA CONSULTING SCF Srl ensures the confidentiality of the whistleblower’s personal data, as well as protection from any retaliatory conduct of a professional, contractual, or organizational nature, and from any action or omission that may constitute a form of retaliation, penalization, or direct or indirect discrimination against them for reasons directly or indirectly connected to the report submitted. Protection measures are also extended to third parties involved.


TYPES OF IRREGULARITIES THAT MAY BE REPORTED*:

Reports may concern behaviors, acts, or omissions that harm the public interest or the integrity of the private entity, of which the whistleblower has become aware in the workplace, and that constitute administrative, accounting, civil, or criminal offenses, etc.

Below are the main regulations whose violation may therefore be subject to reporting:

  • regulations governing financial activities;

  • rules on anti-money laundering and counter-terrorism financing;

  • Organizational and Management Model pursuant to Legislative Decree No. 231/01;

  • rules, laws, regulations, Codes of Conduct, or other company provisions subject to disciplinary sanction.

* The Whistleblowing channel is not intended for complaints or for forwarding commercial requests or matters, nor for disputes relating to the employment relationship.


HOW TO SUBMIT A REPORT:

Internal Company Channels

Report via certified e-mail (PEC)

The e-mail must be sent to the Internal Reporting System Manager (Compliance Officer) at the following address:
segnalazioni.ifaconsulting@pec.it

Credentials have been provided to all relevant parties.

External Channels

While emphasizing the importance of using internal channels, whistleblowers may submit an external report to the National Anti-Corruption Authority (ANAC), following the procedures provided on the Authority’s official website, if, at the time of submission, one of the following conditions applies:

  • there is no mandatory internal reporting channel in the workplace, or such a channel is not active or, if active, is not compliant with external regulations;

  • the whistleblower has already submitted an internal report in accordance with the relevant legislation, but no action has been taken;

  • the whistleblower has reasonable grounds to believe that, if they were to file an internal report, it would not be effectively followed up, or that such a report could lead to retaliation;

  • the whistleblower has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest.