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Managemente System for Internal Reports of Violations (“Whistleblowing”)

Espansione Marketing S.p.A. has complied with the requirements of the Legislative Decree 10 March 2023, no. 24 “implementation of the European Directive (EU) 2019/1937 on the protection of people reporting violations of Union law and containing provisions on the protection of people reporting violations of national regulatory provisions” (so-called whistleblowing).

The Decree regulates the protection of people reporting violations of national or European Union regulatory provisions that harm the public interest or the integrity of the public administration or private entity, of which the whistleblower has become aware in the public or private work context (employees, self-employed workers, collaborators, freelancers, consultants, trainees, shareholders, members of administrative and supervisory bodies, etc.).

The provisions of the Decree do not apply to disputes, claims or requests related to personal interests linked to an interest of the reporting person that relate exclusively to employment relationships with hierarchically superior figures.

In particular, reports may only concern unlawful conduct relevant to the 231 discipline or violations of the 231 model and be made only through the internal channel as the Company has not reached the average of 50 workers and has adopted an Organizational Model 231.

The Company has entrusted the management of the reporting channel to the Supervisory Body and has established the following internal reporting channels: 

- in written form, analog, on paper, also by sending a registered letter; it is necessary that the report is placed in two closed envelopes: the first with the identifying data of the reporting person together with a copy of the identification document; the second with the report, so as to separate the identifying data of the reporting person from the report. Both must then be placed in a third sealed envelope that bears the wording "reserved for the Espansione Marketing Supervisory Body" on the outside, to the following address: in via degli Orefici, 152 Blocco 27, 40050 Zona Artigianale Funo (BO);

- in oral form, by requesting a direct meeting with the reporting manager.

The Company guarantees the reporting parties and the other people involved, whatever the channel used, from any form of retaliation and discrimination, ensuring in any case the utmost confidentiality regarding their identity, without prejudice to legal obligations.

In cases where the reports are made with intent or gross negligence, protections are not guaranteed and the reporting or reporting person is subject to a disciplinary sanction.

The Disciplinary System also provides for disciplinary sanctions against those who are found to be responsible for the reported offences.

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