Communication to All Recipients. Whistleblowing Channels

Bonaveri Srl, in compliance with Legislative Decree no. 24 of March 10, 2023, enacted in Bonaveri Srl, in compliance with Legislative Decree no. 24 of March 10, 2023, enacted in implementation of Directive (EU) 2019/1937 concerning "the protection of persons reporting breaches of Union law and laying down provisions for the protection of persons reporting breaches of national legislation," has updated its system for safeguarding individuals who report offenses within the company

To address this requirement, Attorney Francesco De Sanzuane has been appointed as the responsible person for managing the procedure, designated to receive and evaluate reports..

Therefore, the recipient can be contacted through the following means:

  1. The email address [email protected]; it is understood that this email address is managed exclusively by the Recipient to ensure the confidentiality of the reporter's identity.
  2. A letter or note sent in a sealed envelope via postal service or internal mail service (e.g., an internal mailbox for reporters working within the Company, provided by the latter), addressed to the Company's registered office, marked for the attention of the Recipient with the label "Confidential to Whistleblowing Recipient of Bonaveri Srl" or "Confidential to Supervisory Body of Bonaveri Srl." Inside the envelope containing the report, another envelope with the reporter's identifying information must be included. The company's protocol office or the individual collecting communications from the internal mailbox must not open this envelope, and a protocol signature will be affixed to the sealed envelope. This envelope must be promptly delivered to the Recipient or to the Supervisory Body, if present, and then archived and stored by them.
  3. Verbally, through a dedicated telephone line (also noted on the company's notice board) - +(39) 347 369 11 86 - equipped with voice messaging systems, or through a direct meeting, upon the express request of the reporter; and alternatively, if necessary, communication sent through
  4. A dedicated computer platform, if and where made available and communicated to the interested parties.

If the report is submitted via the aforementioned computer tool, the reporter's identifying data will be separated from the content of the report and kept apart from it, using a cryptographic system. The identity of the reporter can be disclosed in cases where it is necessary for the defense of the accused party or within the context of any proceedings (disciplinary, criminal, etc.) against them.

In the event outlined in Article 6 of Legislative Decree no. 24 of March 10, 2023, the reporter may approach the competent authorities designated by the new legislation, the so-called external channel, namely:

  • N.A.C., through the dedicated portal on the Agency's website www.anac.it; or alternatively,
  • For Public Disclosures or Complaints, to the judicial and accounting authorities.
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