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					Whistleblowing

				

					
				

			

		

		

			
					

	
						
					


				
		

	





	

		
	





	

		

			
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:
 
         
  • all Credem Group employees;
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  • self-employed workers holding a collaboration relationship, employees or associates of suppliers, freelancers and consultants who carry out their activities for the Group;
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  • volunteers and interns (paid and unpaid);
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  • shareholders and individuals with administrative, management, control and supervisory or representative functions;
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  • job candidates;
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  • employees under probation;
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  • former employees.
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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: 
 
         
  • rules governing banking;
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  • rules governing financial activity;
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  • regulations for the prevention of money laundering and the funding of terrorism;
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  • Compliance Program pursuant to Legislative Decree. 231/01;
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  • rules governing the activities carried out by insurance companies and insurance intermediaries under the Private Insurance Code;
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  • antitrust laws;
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  • rules, laws and regulations, Codes of Conduct or other company provisions subject to disciplinary sanctions.
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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 through digital platform
 
 Our internal system allows for submitting a report through a dedicated digital platform, available at the following link:
 
credem.integrityline.com
 
B) Reporting via email
 
The email must be sent to the Internal Reporting System Manager (Audit Service Manager) using the email address: 
 
RSI.segnalazioni@credem.it
 
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.segnalazioni@credem.it. 
 
C) Paper-based reporting

Any 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 AUDIT
Credito Emiliano S.p.A
Via Emilia San Pietro, n. 4
42121 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.
 
D) 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)
 
External Channels
 
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:
 
         
  • within the whistleblower's organization, the mandatory activation of the internal reporting channel is either not foreseen or has not been actived or, even if activated, the system does not comply with external regulations;
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  • the whistleblower has already made an internal report in accordance with the relevant external legislation, but this has not been followed up;
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  • the whistleblower has reasonable grounds to believe that, if they were to make an internal report, this would not be followed up effectively, or that it could leave them exposed to the risk of retaliation;
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  • the whistleblower has reasonable grounds to believe that the violation may constitute an imminent or obvious threat to the public interest.
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Attachments :
    
›› Privacy Policy - Whistleblowing and Violations of the Code of Conduct
  
›› Group Regulation - Internal violation reporting system