Whistleblowing

Whistleblowing is a tool through which employees (and others) of a company, report to specific individuals or bodies a violation, crime or wrongdoing, committed by others in the organization.

It has been in Italy since 2017, but new legislation (Legislative Decree 24/2023) expands the protections afforded to whistleblowers.

Who can make a report?
  • employees (including those in probationary period);
  • Self-employed and collaborators;
  • Employees or contractors of EHT's suppliers;
  • freelancers and consultants who provide their services for EHT;
  • volunteers and paid and unpaid interns who serve for EHT;
  • shareholders and persons with administrative, management, control, supervisory or representative functions for EHT;
  • candidates and potential suppliers.

    Reporting can be done even after the termination of the relationship with EHT
What violations can be reported?

Any criminal, civil, administrative, or accounting offenses, violations of Model 2.3.1. and the Code of Ethics, that harm the public interest or EHT's interest and that have come to one's attention in the work context, provided that the violation is not related to a personal interest that pertains exclusively to one's relationship with EHT.

How can I report?

Using EHT Whistleblowing Platform, which can be reached at this address, by filling in the required fields.
For more precise operational instructions on how to make a report, the EHT Whistleblowing Platform user guide is available in the user support section.
The report will be sent to the Supervis ory Board (SB) of EHT, which is the entity in charge of handling reports.

What should the content of reporting look like?

The content of the report is free, but it is important that as much information as possible be reported in order to facilitate internal investigations.

Reporting can be done:

  • In writing, including a description of the facts;
  • or orally, by audio note;
  • it is also possible to request a face-to-face meeting with the reporting manager (by indicating it on the screen where the description of the facts is requested), to be scheduled within the 7-day period from the reporter's request.
What happens after the report is submitted?

If the report is entered correctly, you will immediately receive a unique confirmation number for the report, which you will need to check the status of the report in real time and interact with the SB.

Within 7 working days, you will receive confirmation from the SB that the report has been taken care of.

Within 3 months of taking the report, you will receive feedback.

Confidentiality

Your identity will remain CONFIDENTIAL and the reporting information will be accessible only and exclusively to the members of the SB in charge of the investigation.

Remember to use only this platform (and not to use e-mail or other means) for all reporting-related communications.

Privacy

In case you decide to make an authenticated report, your personal data will be processed in accordance with the current privacy regulations, as per the notice on the platform.

The documentation and data related to the report will be kept for as long as strictly necessary for the processing of the report (however, no longer than 5 years from the communication of the final outcome of the procedure).

What protective measures am I entitled to if I make a report?

In terms of confidentiality, your identity will not be revealed as part of the internal procedure.

Regarding protection from any recursive acts of your employer because of your reporting, your employer cannot, for example, fire you, change your job description, or apply any unfavorable treatment.

However, your identity could be detected:

  • If you give your consent or you yourself disclose it;
  • In the context of court proceedings.
Do the protective measures apply only to the reporter?

No, they also apply to:

  • to FACILITATORS, that is, colleagues who assist you in the reporting process;
  • to your FAMILIARS who work in the same work setting;
  • to your COLLEGES with whom you have a regular and current relationship;
  • to any ENTITIES YOU OWN OR FOR WHICH YOU WORK, as well as to entities operating in the same work environment.
What happens if my report is false?

Caution: reporting should be done in good faith and only if you have good reason to believe that the information about the violations is true.

If it were determined that you made a WILLFUL report, you could receive a DISCIPLINARY SANCTION and be subject to charges of slander or libel.

For this reason, it is very important that reporting is done seriously and in good faith.

In what cases can I make an external report (to ANAC)?

Only if:

  • you have already made the internal report, but it has not been followed up;
  • you have well-founded reasons To believe that:
    • internal reporting will not be effectively followed up;
    • there is a risk of retaliation;
    • the violation may constitute imminent or obvious danger to the public interest.

To whom can I make an external report?
To the National Anticorruption Authority (ANAC) by logging on to the following link

Can the report be made public?

Caution: public disclosure in the breach (i.e., through the press, electronic media, or otherwise means of dissemination capable of reaching large numbers of people) may prevent you from obtaining the protections provided by the law.

Unless you fall into one of these cases:

  • you made the internal and external reporting without getting any feedback;
  • you have good reason to believe that the violation may constitute an imminent or obvious danger to the public interest;
  • you have a well-founded reason to believe that external reporting may compromise the risk of retaliation or may not be effectively followed up due to the specific circumstances of the particular case.

Submit your report