Governance

Reports of violations can be made by:

• workers with an employment contract (short-time and flexible work; fixed-term work; job agency; apprenticeship; ancillary work) or occasional service contract;
• self-employed workers and holders of collaborative relationships who carry out their work at Gervasoni SpA;
• suppliers of goods and services or subjects who carry out works in favor of Gervasoni SpA;
• freelancers and consultants who work for Gervasoni SpA;
• volunteers and interns, paid and unpaid, who work for Gervasoni SpA;
• the shareholders and people with administrative, management, control, supervisory or representation functions (even exercised on a purely de facto basis) of Gervasoni SpA.

Pursuant to Legislative Decree no. 24/2023 and taking into account the context in which the Company operates and its organizational and structural characteristics, the following may be subject to reporting:

• significant illicit conduct pursuant to Legislative Decree 8 June 2001, n. 231;
• violations of the Organization, Management and Control Model pursuant to Legislative Decree 8 June 2001, n. 231, of the Code of Ethics and/or of the procedures of the internal regulatory system of Gervasoni SpA;
• offenses that fall within the scope of application of European Union or national acts, or national acts that constitute the implementation of European Union acts relating to the following sectors: public procurement; financial services, products and markets and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental Protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; protection of privacy and protection of personal data and security of networks and information systems;
• acts or omissions detrimental to the financial interests of the European Union;
• acts or omissions concerning the internal market;
• acts or behaviors that frustrate the object or purpose of the provisions of the European Union in the sectors indicated in the previous points;
• administrative, accounting and criminal offenses that do not fall within the previous points.

The following cannot be reported: disputes, claims or requests linked to a personal interest of the Reporter and reports based on information that the Reporter knows to be false.

In compliance with the provisions of the applicable legislation, Gervasoni SpA, having consulted the company trade union representatives, has established specific internal reporting channels which the Whistleblower can use.

Management platform

The Report can be made, anonymously or non-anonymously, through the Whistleblowing Platform (“Platform”), which can be accessed from segnalazioni.gervasoni.com

The insertion of the Report via the Platform is carried out by completing a questionnaire which requires the detailing of some elements.

At the end of the process, the Platform issues the Report’s identification code to the Reporter: this is a unique 16-digit code that the Reporter must keep to subsequently access the Platform, check the status of the Report, receive feedback in this regard or make specific additions.

In the ‘Management Procedure’ section, the Company makes clear information available to all potential reporters with references to the Platform itself and the use procedures (see paragraphs 5.1.1 and 5.1.2 of the document attached in the section), including the prerequisites to carry out the Reports (see paragraph 4.4) and the internal management method (see paragraph 5.4).

Oral reporting

If the Whistleblower requests it, a direct meeting may be set up with the Persons In Charge of managing the Reports (Whistleblowing Team). In this case, the Report, with the prior consent of the Reporter, will be documented by recording on a device suitable for storage and listening. If the Reporter does not give his consent to this method, a minute of the meeting will be drawn up, which the Reporter will be able to verify, rectify and confirm by signing.

For both methods, the data and documentation collected during the direct meetings are kept for the time necessary to manage the Report, and in any case no later than five years from the date of communication of the final report of the process (see paragraph 5.4.3 of the Procedure). After this deadline, the Reports and the related documentation are deleted and/or destroyed from all media and archives.

As part of the reporting management process, personal data are processed in compliance with current legislation (EU Regulation 679/2016 and Legislative Decree 196/2003, as amended by Legislative Decree 101/2018).

Information on the processing of personal data can be found below.