Whistleblowing

So.Ge.A.Al. S.p.A. has adopted a Reports Management process, updated in light of Legislative Decree of 10 March 2023, no. 24, implementing Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, on the protection of persons who report breaches of Union law, and containing provisions on the protection of persons who report breaches of national regulatory provisions.

Who can submit a whistleblowing report

The following persons operating within the Company’s work context may submit a report:

  • Employees

  • Self-employed workers

  • Collaborators, freelancers and consultants

  • Volunteers and trainees, whether paid or unpaid

  • Shareholders and persons with administrative, management, control, supervisory or representative functions, even where such functions are exercised purely in practice

How to submit a whistleblowing report

In order to ensure the effectiveness of the reporting process and provide broad and indiscriminate access to all those wishing to submit a report, So.Ge.A.Al. S.p.A. makes available a number of alternative reporting channels, specifically:

  • An online platform, accessible at https://whistleblowingsogeaal.segnalazioni.net, which allows reports to be submitted in written form (by completing the provided fields) and oral form (by recording one’s voice or by requesting a direct meeting with the persons specifically authorised to collect reports), either in nominative mode (registered user) or anonymous mode (unregistered user)

  • Ordinary post, to the address of the Sogeaal S.p.A. Supervisory Body 231: Organismo di Vigilanza 231 c/o Sogeaal SpA, Regione Nuraghe Biancu, 07041 Alghero SS

What can be the subject of a whistleblowing report

A whistleblowing report may concern conduct, acts or omissions that harm the public interest or the integrity of the Company, consisting of:

  • Violations of national regulatory provisions, such as administrative, accounting, civil or criminal offences, unlawful conduct relevant under Legislative Decree 231/2001 or violations of the Company’s Model 231 and its annexes

  • Violations of European regulatory provisions, such as offences falling within the scope of European Union acts relating to specific sectors including, by way of example but not limited to, public procurement, financial services, products and markets, etc.

Reports must be duly substantiated in order to allow the assessment of the facts, and must be based on precise and consistent factual elements. In particular, the following must be clearly stated:

  • The time and place in which the reported event occurred

  • A complete description of the facts

  • Personal details or other elements that allow identification of the person to whom the reported facts are attributed

Receipt and management of the whistleblowing report

The Company’s Supervisory Body 231 is responsible for receiving and managing reports. Once a report has been received, it will be analysed and the facts contained therein verified by the Supervisory Body, which will take charge of the report in compliance with the principles of impartiality and confidentiality, carrying out any activity deemed appropriate. All personal data will be processed in accordance with current Privacy regulations, in full respect of fundamental rights and freedoms, with particular regard to the confidentiality of the identity of the persons involved and to the security of processing, also as provided for by the Whistleblowing Decree.

For further details, please refer to the Whistleblowing Policy.

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