Whistleblowing
The Intermonte Group promotes and encourages a corporate culture of legal compliance, featuring correct behaviour, and guarantees effective and efficient channels for the prevention, management and if required, safe and confidential internal reporting of any irregularities or breaches of the rules governing company activity.
In this regard, Intermonte demands the highest standards of honesty and integrity from its employees and collaborators in the performance of their duties, as well as the safeguarding of the resources for which each is responsible.
How to report issues internally
An internal whistleblowing channel has been made available for the reporting of any breaches of the rules governing Intermonte's activity. The channel is managed directly by the "Head of Internal Reporting Systems", and can be used to report alleged anomalies or breaches by employees, former employees, recruitment candidates, shareholders, members of Corporate Bodies, external and occasional freelancers, subcontractors and suppliers, using the following methods:
- Written notification, through completion of the Whistleblowing Form, sent by traditional post to: Intermonte Sim S.p.A., Galleria de Cristoforis, 7/8, 20122 Milan MI – in an envelope marked as private and confidential and for the attention of the “Head of Internal Reporting Systems”. The appropriate form is included as (Appendix 1).
In this case, in order to guarantee confidentiality, the report must be placed in two closed envelopes:
- the first containing the identity of the whistleblower, together with a photocopy of their ID document;
- the second containing the report itself. This is in order to ensure the identity of the whistleblower remains separate from the content of the report.
Both envelopes must then be placed in a third closed envelope marked as "reserved" for the Head of Internal Reporting Systems. The report will be treated according to confidentiality protocols.
- Verbal report, by telephone on +39 02 77115650 or by requesting, with due notice, a direct in-person meeting with the Head of Internal Reporting Systems; in this case, with the consent of the whistleblower, the meeting will be recorded in order to process the report.
If the internal report directly concerns the Head of the Compliance Department or a department employee, it may be sent by traditional post to: Intermonte Sim S.p.A., Galleria de Cristoforis, 7/8, 20122 Milan MI – , in an envelope marked as private and confidential and for the attention of “Chairman of the Supervisory Function”, using the same methods indicated above.
Chi può segnalare
Le segnalazioni possono essere effettuate dalle seguenti persone che prestano la loro attività lavorativa o intrattengono rapporti con Gruppo Intermonte:
- i lavoratori dipendenti (qualunque tipologia contrattuale), gli stageur, tirocinanti;
- i consulenti finanziari;
- i soggetti terzi che intrattengono rapporti e relazioni d’affari durevoli con la SIM (e.g. collaborazioni coordinate e continuative, consulenti stabilmente inseriti in azienda sulla base di rapporti time material, etc.);
- i fornitori di beni e servizi;
- le persone con funzioni di amministrazione, direzione, controllo, vigilanza o rappresentanza;
- gli azionisti.
Who can make internal reports
Reports can be made by the following people who work for or have professional relationships with the Intermonte group:
- employees (on any type of contract), interns and trainees;
financial advisors; - third parties who have lasting business relationships with the SIM (e.g. coordinated ongoing working relationships, consultants working regularly with the company on the basis of time and material contracts, etc.);
- suppliers of goods and services;
- persons with administrative, management, control, supervisory or representative functions;
- shareholders.
What can be reported
By way of example, reports may be made relating to:
- breaches of the Organisation and Management and Control Model adopted pursuant to Legislative Decree 231/2001 (e.g. crimes against public sector institutions, corruption between private individuals, corporate crimes, computer-related crimes, etc.);
- breaches of regulations relating to the prevention of money laundering and the financing of terrorism;
- breaches of data protection legislation;
- breaches of competition law;
- gender discrimination and sexual harassment;
- damage/fraud perpetrated to the detriment of the Company or third parties;
- conflicts of interest.
These channels should not be used to raise personal complaints or grievances.
External channels
The legislation also envisages making an external report directly through the channels activated by the competent authorities, if at least one of the following conditions is met:
- the internal report made was not followed up;
- there are reasonable grounds to believe that, if an internal report were made, it would not be effectively followed up or could entail the risk of retaliation against the whistleblower;
- the whistleblower has reason to believe that the breach may constitute an imminent or clear threat to the public interest.
The external reporting channels currently activated by the competent supervisory authorities that pertain to Intermonte’s activities can be consulted at the following links:
- ANAC: www.anticorruzione.it
- Bank of Italy: www.bancaditalia.it/compiti/vigilanza/whistleblowing/index.htm
- Consob: www.consob.it/web/area-pubblica/whistleblowing
