Reports of alleged irregularities
What is “Whistleblowing”?
The term Whistleblowing refers to the reporting by an individual, known as the “reporter” (in English “whistleblower”), of illegal conduct or an irregularity committed within a corporate context with which they have a qualified relationship or perform any kind of activity (shareholder, director, employee, self-employed worker, intern, volunteer), of which they have been a witness or have become aware, deemed harmful to the public interest or the integrity of the company.
Why is it so important to make a report?
CIM confirms its commitment to act with the highest standards of honesty and loyalty.
This commitment is essential both for the strictest compliance with laws and regulations and for constantly earning and maintaining the trust of our clients, shareholders, employees, and business partners.
In this context, CIM is committed to protecting individuals who report violations, as a valuable and essential contribution to the proper pursuit of the described objectives.
In particular, CIM encourages prompt reporting of any action, omission, or practice deemed inappropriate or non-compliant with laws, regulations, the Organization, Management and Control Model, the Code of Ethics, and any internal policy or procedure.
The report is therefore primarily a preventive tool.
If the report is sufficiently detailed and complete, it can be promptly and easily verified, allowing for the immediate adoption of necessary initiatives to prevent the risk from materializing into illegal situations or, if already underway, to ensure its immediate cessation, except for the initiation of disciplinary proceedings and possibly recourse to judicial authorities.
What can be reported with Whistleblowing?
- actual or potential violations, of which there is knowledge or even just a reasonable suspicion,
- conduct presumed to be inappropriate, incorrect, unethical, or illegal (or even just potentially illegal or seemingly illegal),
- any crime, even in the form of an attempt, or administrative offenses, that have occurred or are possibly verifiable, as well as the concealment perpetrated or attempted of such violations, conduct, or crimes.
- corruption;
- conflicts of interest;
- money laundering, terrorist financing, or violation of sanctions;
- fraud (policy forgery, false claims, etc.);
- fraudulent financial statements (false accounting, etc.) or of other kinds;
- threats, discrimination, physical or moral harassment, other inappropriate actions or contrary to corporate values and ethics;
- embezzlement (secret data, assets, etc.), waste or misuse of assets;
- endangerment of health, life, and safety;
- other violations of laws, rules, and regulations.
In addition to the examples listed above, conduct related to other dedicated regulatory areas is also relevant.
What cannot be reported?
Reports cannot concern personal grievances of the reporter, claims, or requests related to the employment relationship.
Reports cannot be used for purposes other than those indicated above or that belong to interpersonal relationships.
How can a report be made?
CIM encourages prompt reporting of any practice or action deemed inappropriate or non-compliant.
To this end, CIM provides various communication channels (with the possibility of a personal meeting), through which it is possible to make the report, either nominatively or anonymously:
- reporting tool accessible at the link https://cim40.segnalazioni.eu/#/
It is suggested to prefer this mode of communication as the channel is designed to ensure maximum confidentiality and security of reports and reporting individuals, in compliance with current regulations; - local email address segnalazioni.whistleblowing@cim40.com accessed exclusively by the Internal Audit manager and expressly authorized members of the Internal Audit Function (Team Investigation); in line with regulatory dictates, it is preferable to use this channel for requesting an appointment aimed at verbally presenting the report;
