Legislative Decree of 10 March 2023, No. 24, implementing EU Directive 2019/1937, regarding “the protection of persons reporting breaches of Union law and containing provisions concerning the protection of persons reporting breaches of national regulations”, entered into force on 15 March 2023 and has been operational since 17 December 2023 for organizations that have adopted an Organization, Management, and Control Model pursuant to Legislative Decree of 8 June 2001, No. 231, or have more than 50 employees.
What Can Be Reported
According to the above legislation, reportable conduct includes acts or omissions that harm the integrity of the Foundation, specifically:
- Administrative, accounting, civil, or criminal offences;
- Unlawful conduct under Legislative Decree 8 June 2001, No. 231, or violations of the Organization and Management Model adopted by the Foundation;
- Breaches falling within the scope of EU or national regulations relating to: public procurement; financial services, products and markets; prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety, animal health and welfare; public health; consumer protection; privacy and personal data protection; and network and information system security;
- Acts or omissions damaging the EU’s financial interests;
- Acts or omissions concerning the internal market;
- Acts or conduct that defeat the purpose of the provisions set forth in EU law.
Who Can Report
Reports can be made by:
- Employees or collaborators;
- Suppliers, subcontractors, and their employees or collaborators;
- Freelancers, consultants, and self-employed workers;
- Volunteers and interns, whether paid or unpaid;
- Shareholders or individuals with administrative, management, supervisory, control, or representative functions;
- Former employees or collaborators;
- Persons who no longer hold any of the above positions if the information was obtained during the relationship;
- Individuals in the process of being recruited, on probation, or whose relationship with the entity has not yet started.
Report Handling
Reports are managed by the Whistleblowing Report Manager, who ensures compliance with personal data protection laws and the confidentiality of the whistleblower, the persons involved, and any third parties mentioned. Reports must be relevant to the purposes set out in Legislative Decree No. 24/2023.
Malicious or bad-faith reports may be dismissed, and identifying details of the persons involved may be removed.
How to Report
The Foundation provides an internal reporting channel through a dedicated online form that ensures confidentiality and data security.
It is also possible to submit reports in paper form to:
FONDAZIONE CASA DI RIPOSO R.S.A. PAOLO VI ONLUS
Via Achille Pedrocca, 7 – 25021 Bagnolo Mella (BS) – Italy
(Please write on the envelope: “Reserved for the Whistleblowing Report Manager”)
No dedicated email address or direct meeting request system is currently provided, as the official submission channel is the online form.
Reference to Regulations
For all matters not expressly covered herein, please refer to Legislative Decree No. 24/2023 and the internal Whistleblowing management regulations adopted by the Foundation.