Whistleblowing policy

ZAITEX is a company that fosters an open corporate culture of ethics, transparency and accountability, guided by core values: respect, trust, integrity and inclusion.

Since with Legislative Decree No. 24 of March 10, 2023, Directive (EU) 2019/1937 regarding the protection of persons who report violations of Union law (so-called Whistleblowing Directive) has been implemented in the corporate system, ZAITEX provides a channel for reporting information referable to company personnel and/or third parties related to violations of laws and regulations, the Group’s Code of Ethics and Conduct, the 231 Organizational Model, and ZAITEX’s system of rules and procedures. These channels are not available for commercial complaints or disputes and requests related to personal interests.

In order to implement the provisions introduced by Legislative Decree 24/2023, a Procedure has been adopted that provides clear operational indications about the subject, recipients, mode of transmission and handling of reports concerning violations, as well as about the protection measures provided.

Who can send reports?

By way of example but not limited to, reports may be sent by employees, self-employed workers, holders of a collaborative relationship, freelancers, consultants, trainees, suppliers, shareholders, or persons with administrative or control functions in group companies, such as Board Members or members of Boards of Statutory Auditors.

What is possible to report?

As a general rule, the report may concern all conduct relevant under Legislative Decree 231/01 or involving alleged or ascertained violations of Model 231 or the Code of Ethics, to which must be added offenses of EU matrix and relevance and therefore affecting the financial interests of the European Union.

Reports that do not fall within the objective scope of the regulations will not be taken into consideration.

How to report?

ZAITEX has a dedicated internal reporting channel to which the whistleblower can resort, a customized online portal, which ensures compliance with all necessary legal requirements, including those provided for the organization and management of personal data processing and compliance with the requirements of privacy legislation (Legislative Decree No. 196/2003 – Code on the Protection of Personal Data; EU Regulation 2016/679 on the Protection of Personal Data).

The platform allows all internal and external stakeholders to send reports to predetermined internal individuals authorized to handle the report in order to ensure effective and confidential communication.

Access to the platform is via the following link.

To the platform

Who receives the report?

ZAITEX has outsourced the receipt and processing of reports so that it has sufficient guarantees in terms of specialized knowledge, reliability, and resources to put in place technical and organizational measures to ensure compliance with confidentiality, data protection, and secrecy.

Other reporting and dissemination channels

external reportingchannel managed byANAC, available at https://www.anticorruzione.it/-/whistleblowing: whistleblowers may resort to it residually and only in certain hypotheses indicated in the information document;
public disclosure through the press or social networks: whistleblowers may resort to it further residually and only in certain hypotheses indicated in the disclosure document.