The Whistleblowing Reporting System
Credem Group believes Whistleblowing to be an important tool to prevent, avoid or block potentially harmful unlawful actions, while, at the same time, fostering a culture of transparency and integrity.
Who can report wrongdoings in an organisation?
Following the provisions set out in Legislative Decree 24/2023, the range of persons who can make a Whistleblowing report has been expanded to include:
In compliance with internal policies and external regulations, the Credem Group guarantees that the whistleblower's identity and personal data remain confidential, and that they are shielded against any retaliation of a professional, contractual or organizational nature and against any action or omission that could amount to some form of retaliation, penalization or direct and/or indirect discrimination against them for reasons directly or indirectly connected to the report made. Such protection measures are also extended to any third parties involved.
Typical cases of whistleblower reports 1:
The new Decree defines and extends the type of violations that can be reported in terms of any behaviors, actions or omissions that harm the public interest or the integrity of the private entity, of which employees or other stakeholders have become aware in the working environment, and that focus on conduct prohibited by a specific law, e.g. administrative, accounting, civil or criminal offenses, etc...
The main regulations whose breach may be reported by whistleblowers are shown below:
1 The Whistleblowing channel is not designed for reporting complaints or forwarding requests and records of a commercial or transactional nature, or for raising workplace grievances.
How to make a report:
Internal channels of the Credem Group
A) Reporting via email
The email must be sent to the Internal Reporting System Manager (Audit Service Manager) using the email address:
If the whistleblower believes that there might be a conflict of interest, they may make a report to the Additional Internal Reporting System Manager (Compliance Officer) using the email address RSS.email@example.com.
B) Paper-based reportingAny paper-based reports must be sent in a sealed envelope, clearly marked "Personal & confidential", to the following address:
Responsabile del Sistema Interno di Segnalazione (RSI)to the attention of Capo Servizio AUDITCredito Emiliano S.p.AVia Emilia San Pietro, n. 442121 Reggio Emilia
If the whistleblower believes that there might be a conflict of interest, they may mail the report to the Additional Internal Reporting System Manager (Compliance Officer) to the same postal address.
C) Oral reporting via in-person meeting
A report may also be submitted by requesting an in-person meeting with the Internal Reporting System Manager (Audit Service Manager) by calling the number:0522-582111 (ask to speak directly with the Audit Service Manager)
While highlighting the importance of using internal channels, whistleblowers can make an external report to the National Anti-Corruption Authority (ANAC) following the guidelines provided on the Authority's institutional website, if one of the following conditions apply, at the time of its submission: