WHISTLEBLOWING
Internal Reporting under Legislative Decree March 10, 2023, No. 24
(so-called Whistleblowing)
Notice: Castagnari S.r.l. (hereinafter “Company”) has established an internal reporting channel in
compliance with Legislative Decree March 10, 2023, No. 24 (hereinafter “Decree”), concerning reports
of violations that harm the public interest or the integrity of public administration or private entities, as
identified in Articles 2, paragraph 1, letter a) and 3, paragraph 2 of the Decree.
Who can report?
The use of the internal channel is intended for the subjects indicated in Article 3 of the Decree: in
particular, employees and quasi-employees, self-employed workers and collaborators, freelancers,
consultants, volunteers, and interns who perform their activities at the Company, shareholders, and
persons with administrative, managerial, control, supervisory, or representative functions, even if
these functions are exercised de facto, as well as, within the limits of their knowledge of violations in
the work context with the Company, also employees of public administrations; independent
administrative authorities, public economic entities, private entities under public control, in-house
companies, public law bodies, or public service concessionaires. Reporting is also allowed if the
aforementioned relationships have not started, if the information on violations was acquired during
the selection process or in other pre-contractual phases; during the probationary period and after the
termination of the legal relationship if the information on violations was acquired during the relationship itself.
How to report?
Internal reports can be made through the following channels:
• Written channel: by sending a written report by registered mail to the attention of the
Whistleblowing Office, to be sent to the office of the law firm Borgiani Parisella e Associati –
Attn. Lawyer Melissa Basilici, at Via Morbiducci, 21 62100 – Macerata (MC). In any case, the
reporter is invited to insert the report in two sealed envelopes: the first with their identification
data; the second with the subject of the report. Both envelopes should then be placed in a
third sealed envelope, without the sender’s indication, bearing the words “Reserved for the
Whistleblowing Office” on the outside. The envelope can only be opened and managed by the
members of the Whistleblowing Office, in compliance with the confidentiality obligations
provided by the Decree.
• Oral channel: using the dedicated telephone line no. +39 348 140 1425, directly managed by
the Company’s Whistleblowing Office, possibly also leaving a message on the answering
machine. Through the same telephone number, the reporter can also request a direct meeting
with the members of the Whistleblowing Office. The meeting will be held in a place that
ensures the confidentiality of the reporter, if necessary, even outside the Company’s
premises.
Oral reports (by phone or in person) will be recorded, transcribed, or documented by a detailed report
by the Whistleblowing Office. The reporter can verify, correct, and confirm the content of the report
and/or transcription with their signature.
The report, to be made in good faith, avoiding offensive or insulting tones, must indicate:
• Name and surname, qualification, and function/role of the responsible person, if known;
• Circumstances of time and place of the event, along with any other element deemed relevant
for the report;
• Any subjects present at the place of the violation, who can potentially report on the incident;
• Any attached documentation that can confirm the validity of the reported fact;
• Any private interests related to the report;
• Any other information that can facilitate the collection of evidence on the reported matter.
The report must also include the identity of the reporter and the data to be contacted by the
Whistleblowing Office.
How is the report managed?
Reports are received by a dedicated office (“Whistleblowing Office”) that proceeds with the
investigation in compliance with the confidentiality obligations provided by the Decree. Within 7 days
of receipt, the Whistleblowing Office will acknowledge receipt of the report and within the following 3
months will provide feedback on the outcome.
Confidentiality and protections
In application of the Decree, the right to confidentiality of the reporter, the facilitator, and the persons
involved in the report is guaranteed. Any form of retaliation against the reporter is prohibited, who can
enjoy the protection measures provided for in Articles 16 and following of the Decree, if the conditions
are met. The reporter who believes they have suffered retaliation due to the report can notify the
National Anti-Corruption Authority (ANAC) through its institutional channels. Any processing of
personal data is carried out in compliance with the personal data protection regulations.
External reporting
The reporter can make an external report through the channel established and accessible on the
ANAC website in the following cases:
• The internal reporting channel indicated in the Procedure is not active;
• The reporter has already made a report to the channel indicated in the Procedure and it has
not been followed up;
• The reporter has reasonable grounds to believe that if they made an internal report through the
channel provided by this Procedure, it would not be followed up or the report could pose a risk
of retaliation;
• The reporter has reasonable grounds to believe that the violation to be reported may
constitute an imminent or obvious danger to the public interest.
For the use of the external reporting channel or for resorting to public disclosure, in the cases
provided by the Decree, please refer to the guidelines and the official ANAC website.
For more information, please consult the full procedure and the attached privacy notices, available at
the following links:
