Reporting Procedure for Abuse, Harassment and Wrongdoing

1. Purpose

The main purpose of this Reporting Procedure is to guide personnel, external collaborators andstakeholders of Vernay Italia S.r.l. Unipersonale, when reporting:

2. Regulatory References



3. Purpose of a Whistleblowing Report

Safeguarding of the public interest or integrity of Vernay Italia S.r.l Unipersonale (a report is not devised to protect personal interests) and, in relation to UNI. PdR 125/2022, to protect workers in case of abuse or harassment in the workplace.

4. Who Can Make a Report

Persons who work in or with Vernay Italia S.r.l. are eligible to make reports:

5. When a Report May be Made

6. What Can Be Reported

A whistleblowing report must involve infringements that fall within the scope of Article 2 of Legislative Decree 24/2023 and UNI.PdR 125/2022.

The legislation defines infringements as any conduct, acts or omissions that are likely to harm the public interest or the integrity of the company, which have come to the attention of the reporting party in the course of his/herwork, and which consist of:

By express legislative provision, the whistleblowing provisions do not apply (Article 1 of Legislative Decree 24/2023) to:

In relation to UNI PdR 125, discrimination, abuse and harassment based on gender may be reported, where they involve:

7. Elements Necessary for Reporting

A report must be as detailed as possible, so that the facts may be assessed by those responsible for receiving and handling reports.

The following elements must be crystal clear:

Documents may usefully be attached if they can provide evidence of the facts being reported.

8. Manner of Transmission of Whistleblowing Reports

In accordance with the provisions of the regulations, the reporting party may send his/her report: via the portal https:/ or by the following means:

The internal channel is prioritized over the external channel

The reporting party person may make an external report if one of the following conditions is met at the time of its submission:

For detailed procedures for the handling of external reports, please refer to the relevant ANAC Guidelines published on

9. Handling of Anonymous Reports

Anonymous reports are those where the reporting party’s identity is not disclosed. They are equated to ordinary reports, provided that they are detailed, and the reporting party will not be able to avail of the safeguards provided by Legislative Decree 24/2023.
If anonymous reports are received, and they contain sufficiently detailed information or purport to disclose facts of particular gravity, further information may be requested using the same channel, in order to allow for further investigation, with a 15 day deadline being allocated. If the reporting party subsequently reveals his or her Identity, there is an obligation to apply the safeguards provided by Legislative Decree 24/2023.

10. Who Handles Whistleblowing Reports

In compliance with Article 4 of Legislative Decree 24/2023 and UNI PdR 125/2022, whistleblowing reports will be received and managed by an independent committee within the Multinational Group to which the company belongs, composed of the following figures:

11. Protection of the Whistleblower

Article 17 of Legislative Decree 24/2023 contains rules aimed at preventing or nullifying the effects of acts or measures in retaliation against reporting parties for any disclosure of information (dismissal, suspension, non-promotion, change of duties, disciplinary measures, early termination, cancellation of a contract for the provision of goods or services). Other individuals are also protected from retaliation if – although they did not directly submit the report – they are nevertheless deemed to require protection. This category includes “facilitators,” i.e., persons who assist the whistleblower in the reporting process and whose activities must remain confidential, as well as third parties linked to the reporting party such as colleagues and family members, and also legal persons associated with the whistleblower. Protection is waived if the whistleblower is found criminally liable for slander and/or defamation.

12. Protection of the Reported Party

A report, in itself, is not enough to initiate disciplinary proceedings against the party against whom the report has been made. Further to checks in situ and investigative activities, contact will be made with the party against whom the report was made, who will be guaranteed the right to clarify any matters as necessary.

13. Privacy Protection

Personal or sensitive data contained in the report, including data related to the identity of the whistleblower or of other individuals, will be handled in compliance with personal data protection rules and with the provisions of the GDPR Policy adopted by the company.
Reports are handled by Vernay Italia S.r.l. in compliance with regulatory whistleblowing requirements (Law 179/2017, EU Directive 1937/2019, Legislative Decree 24/2023), and with the Italian Anti-Corruption Authority (ANAC) Resolution no. 311 of July 12, 2023.

14. Disciplinary and Sanctions System

Any forms of abuse of this Procedure, such as reports that prove to be unfounded or made with malice or gross negligence, or those that are manifestly opportunistic and/or are made solely in order to harm the reported party or other persons, and any other instance of improper use or instrumentalization of this Procedure, shall trigger liability in disciplinary and/or other specifically legal proceedings. Any ascertained infringements of measures whose purpose is to protect the whistleblower, including any discriminatory acts adopted by the company against the whistleblower, shall also be sanctioned.

Disciplinary sanctions shall be proportionate to the magnitude and seriousness of the unlawful conduct found, and they may include termination of the employment or consulting relationship, in compliance with applicable provisions of law and of the rules of the National Collective Labor Agreement for the relevant sector.

For sanctions, reference is made to the Disciplinary System of the Organization, Management and Control Model pursuant to Legislative Decree 231/2001.

The retaliatory or discriminatory dismissal of the reporting party, the alteration of duties and any other retaliatory or discriminatory act or measure taken as a direct result of the whistleblowing report – shall be null and void.
If a dispute should arise involving the imposition of sanctions or de-skilling measures, dismissal, job transfer or involving direct or indirect organizational measures that undermine the reporting party’s working conditions after the report is made, then the employer Vernay must be able to demonstrate that such measures were adopted for legitimate reasons unconnected with the report.

If the reporting party is an employee of the company who believes that he or she has suffered discrimination as a result of having filed a report, he/she may describe in detail the discrimination that has occurred and transmit the description to the relevant labor organizations, to the National Labor Inspectorate, or directly to the National Anti-Corruption Authority (ANAC) through the appropriate Whistleblowing procedure on its institutional website.

15. Procedure Approval and Publication Process

This procedure is adopted by the Board of Directors and published on the Corporate Intranet.

16. Revision

Original by Vanna Villata, November 2023
Revision by Patrizia Prasso, January 2024