Channel for reporting irregularities
In compliance with the obligations set out in Legislative Decree 24/2023 and in order to foster the spread of a culture of legality, we invite you to report – via the Platform or in the other ways indicated in the Whistleblowing Policy – any suspected or actual irregularity. We guarantee total anonymity and confidentiality throughout the Whistleblowing process.
Warning! It is important that You carefully read and understand the contents of both the Whistleblowing Policy and the Privacy Policy before submitting a Whistleblowing Report. You should not send any personal data that is not strictly relevant to the Whistleblowing Report.
The following is a brief summary, certainly not exhaustive, of the Procedure.
The Complaint
For the Report to be taken into account, it must be as detailed as possible in order to allow an adequate assessment of the facts by the persons competent to receive and handle it.
It is necessary, in particular, that it is clear:
_ the circumstances of time and place in which the fact subject of the Report occurred;
_ the description of the fact;
_ the generalities or other elements that make it possible to identify the subject to whom the facts reported are attributed;
_ the particulars of any other persons who may report the same facts;
_ the declared exclusion of the existence of private facts connected with the Report, so as to exclude that the Report was made for personal purposes, claims or retaliation.
How to make The Complaint
You can make a Report either in written or oral form.
In particular, you can report in writing:
_ by e-mail, using the address segnalazionigreenwich@odvlawfirm.it;
_ by text message on +39 3404950277;
_ by postal service, by sending the document in a sealed envelope addressed to “OdV di Greenwich s.r.l.” at the registered office in Calusco d’Adda (BG) at via Vittorio Emanuele II no. 179 (post code 24033) or to lawyer Francesco Cioppa with office in Milan at via F. Filzi no. 2 (post code 20124);
_ through the Platform.
Here you will find the Operating Instructions for the use of the Platform.
If you do not intend to use the IT Platform, in order to facilitate the entry of information we have however prepared a Reporting Form that we invite you to use.
You can make an oral Report by contacting the Supervisory Board directly on +39 3404950277, with the possibility of requesting a meeting and agreeing, within a reasonable period of time, on a time, place and method.
Responsability
Reporting an offence is an appreciable and civilised act of responsibility of which you should be aware.
Given the significant impact that a Report may have on the persons involved, before sending it, you must be fully aware of the responsibilities and consequences – civil, criminal and possibly disciplinary – that you may incur in the event of false and/or misleading declarations and the formation or use of false documents.
You must in any case expressly declare that you have no competing interests with those of the Reported Person and that the Report is not made for personal purposes, for claims or retaliation.
Reports made in bad faith will be severely punished from a disciplinary point of view and may also have serious consequences of a criminal and/or civil nature.
Anonymity and confidentiality
You may send a Report by indicating your personal details or by remaining anonymous. Even if you decide to send an open Report (i.e. by indicating your personal details), the confidentiality of the personal data and information contained in the Report and those received by the persons involved in the procedure will be guaranteed. The obligation to maintain the utmost confidentiality on the identity of the Whistleblower and on the subject of the Report concerns all the persons who become aware of it or who will be involved in the relevant Procedure.
Prohibition of retaliation
We shall not permit or tolerate any form of retaliation or discriminatory measure or any behaviour, act or omission, even if only attempted or threatened, against you and the other persons involved by reason of the Report.