General information
Digit’Ed has set up an internal whistleblowing system for reporting actions or situations suspected of infringing the laws and regulations governing the company’s business and other cases of non-compliance (e.g., breaches of the company’s organization and management model).
Who can blow the whistle?
In accordance with the provisions of Italian Legislative Decree 24/2023, whistleblowing reports can be made by:
– employees and freelancers who work or have worked for Digit’Ed;
– workers or contractors who provide goods or services or perform jobs for third parties and who work or have worked for Digit’Ed;
– external professionals and consultants who work or have worked for Digit’Ed;
– volunteers and trainees (whether paid or unpaid), interns, workers on fixed-term and project-based contracts, and temping workers;
– shareholders (natural persons);
– persons tasked with executive, controlling, oversight or representation functions (hereinafter key management personnel);
– members of the Supervisory Body.
The whistleblowing procedure allows confidential reports to be made of infringements that harm the public interests or integrity of Digit’Ed, of which the whistleblower has learned through his or her work, or on the basis of his or her legal-economic relationship with the company, with measures in place to protect the whistleblower from the possibility of retaliatory or discriminatory actions.
How to blow the whistle
Whistleblowing reports can be made through the specific channels indicated below (open 24/7, in Italian).
Reports should preferably be made in non-anonymous form so as to allow identification of the whistleblower (given and family names, relationship with the company, and contact details) and should contain a circumstanced description of the actions and situations suspected to infringe laws and regulations. Where possible, indication should be made of the procedures and rules alleged to have been infringed and any useful information for investigating the allegations. Finally, the whistleblower is required to declare whether they hold a personal interest connected to the report.
Anonymous reports will only be accepted where they are adequately circumstanced and able to bring to light specific situations and actions. They will be taken into consideration only where, on a prima facie basis, they do not appear irrelevant, without foundation, or uncircumstanced.
Internal channels set up by Digit’Ed
Whistleblowing reports can be made in writing via registered mail with return receipt to the address:
Organismo di Vigilanza 231—Digit’Ed S.p.A.—via San Vigilio 1, 20142 Milan (to report infringements or attempted infringements of the company’s organization and management model)
Internal Audit—Digit’Ed S.p.A.—via San Vigilio 1, 20142 Milan (for other infringements)
To protect the identity of the whistleblower, the alleged infringer, and any other person mentioned in the report, as well as the confidentiality of the report itself and the relative documentation, we suggest enclosing the report in two sealed envelopes, with the first envelope containing the identification details of whistleblower and a copy of his/her ID and the second envelope containing the details of the report. The two sealed envelopes should then be enclosed in a third envelope with the wording “reserved for the whistleblowing officer” on the front.
To facilitate whistleblowers in sending reports, the company provides the following form.
Whistleblowing reports can also be made by phone (unrecorded call) by calling the number:
+39 3666564744 (reports in Italian).
The specific channels set up for handling whistleblowing reports are segregated and independent from ordinary contact channels.
Whistleblowers can additionally request, via either of the two channels indicated above, a meeting in person to make their report. The meeting will be organized without undue delay with a member of the Whistleblowing Team.
The personal data and information acquired by Digit’Ed will be processed by the company in its capacity as Data controller for the purposes of handling the report, on the legal basis of compliance with a statutory obligation. The data will be stored for no more than five years from the final outcome of the procedure.
EXTERNAL CHANNELS to Digit’Ed
Whistleblowing reports should first be made, on a priority basis, via the internal channels set up by the company. Only under certain conditions, an external report can be made directly to the competent authorities.
Specifically for Italy, an external whistleblowing report can be made to the National Anti-Corruption Authority (ANAC) where one of the following conditions holds at the time of the report:
– there is no mandatory requirement for the company of reference to set up an internal whistleblowing system, or such a system has not been activated or, if activated, it does not comply with the regulatory framework;
– the whistleblower has already made a report via internal channels and there has been no follow-up on the report, where follow-up means action taken by the officer in charge of managing the whistleblowing channel to investigate the allegations of the report, the outcome of the investigations, and any measures adopted;
– the whistleblower has reasonable grounds to believe that an internal whistleblowing report would not be followed up or that such a report would raise the risk of retaliation;
– the whistleblower has reasonable grounds to believe that the infringement may constitute an imminent or obvious danger to the public interest.
External reports to ANAC can be made via the channels indicated on the authority’s institutional website.