Campagnolo S.r.l., aware of the importance of initiating appropriate reporting channels to protect the integrity of the company and ensuring compliance with the principles of legality, propriety and transparency, including vis-a-vis third parties, in performing corporate activities, has taken steps to initiate appropriate corporate reporting channels in compliance with Italian Legislative Decree no. 24/2023 implementing EU Directive 2019/1937.
With this Disclosure, Campagnolo S.r.l. intends to promote the widest distribution among all Recipients of all useful information on the channels, procedures and prerequisites for making internal and external reports.
WHO CAN MAKE A REPORT
Anyone working in the company's workplace as:
- freelancer or collaborator working for the company;
- contractor or consultant working for the company;
- volunteer or intern, paid or unpaid, working for the company;
- administrator, manager, auditor, supervisor or representative, even if only on a de-facto basis, at the company,
even when the legal relationship has not yet commenced, if information about a violation was acquired during the hiring process or other pre-contractual stages or during the probationary period, or after termination of the legal relationship, if information about a violation was acquired during the course of the relationship.
WHICH BEHAVIOURS CAN BE REPORTED
Relevant Reports concern conduct, acts or omissions that harm the public interest or the integrity of the company of which the whistleblower has become aware in the course of their work, consisting of:
- crimes falling within the scope of European Union acts in the following areas: public procurement; services, products and financial markets and prevention of money laundering and terrorist financing; product safety and compliance; transportation safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; privacy and data protection; and network and information system security;
- acts or omissions detrimental to the financial interests of the European Union;
- acts or omissions relating to the internal market, including violations of EU competition and State aid rules and corporate taxation.
- acts or conduct that frustrate the object or purpose of the provisions of the above-mentioned European Union acts.
Excluded from the scope of a Relevant Report are the whistleblower’s personal objections, claims or demands that relate exclusively to their individual employment relationship or inherent to their employment relationship with their superiors.
Information that is patently unfounded, already fully in the public domain, or acquired only on the basis of indiscretions or rumours that are scarcely reliable (gossip) is also excluded.
To ensure proper processing, reports must be as detailed as possible to allow the parties responsible for receiving and handling reports to verify the facts. In particular, reports should include:
- details about the time and place where the matter being reported occurred;
- a description of the matter;
- personal details or other elements which make it possible to identify the person to whom the matter being reported can be attributed;
- any attached documents;
- any individuals potentially aware of the matter.
Please note that, to keep their identity confidential and benefit from the protections provided for in the event of retaliation, the whistleblower must specify that they are reporting under this law — the Whistleblowing Law.
Anonymous Relevant Reports are also processed by the Channel Manager to the extent possible. If an anonymous whistleblower is later identified, the same protection measures apply in case of retaliation.
INTERNAL REPORTING CHANNELS
To make it possible to send Relevant Reports, the company, having consulted the unitary trade union representative body, has initiated and keeps open the following reporting channels:
- ordinary mail, address: Campagnolo Srl, WBL Channel Manager, Via della Chimica, 4 - 36100- Vicenza, Italy. To ensure confidentiality, the whistleblower must send the communication in a sealed envelope, explicitly indicating “Segnalazione Whistleblowing” (Whistleblowing Report) on the envelope;
- telephone line from 9 a.m. to 12 noon on working days only at +39 346 680 4295, with forwarding to the Channel Manager. To ensure confidentiality, the whistleblower must communicate that they intend to make a Whistleblowing Report;
- the following online channel: https://campagnolo.integrityline.com/
If the whistleblower requests a face-to-face meeting, it will be arranged by the channel manager within a reasonable time and in a manner that maintains confidentiality.
Campagnolo, in full compliance with the Whistleblowing Decree, guarantees that the above channels ensure the confidentiality of the identity of the whistleblower, the person involved and the person mentioned in the report in any way, as well as the contents of the report and the relevant documentation.
The HR Department, as represented by Chiara Perotto, Maria Pia Zanin, and Giovanni Frison (the “Channel Manager”) is responsible for managing the whistleblowing channel.
For the proper processing of the report, internal or external individuals may be involved who do not have a conflict of interest and who will be bound by the confidentiality requirements laid down in the regulation.
PROCEDURES FOR HANDLING REPORTS
The whistleblowing Channel Manager performs the following activities:
- providing the whistleblower with an acknowledgement of receipt of the report within seven days from the date of receipt;
- communicating with the whistleblower and requesting additional information from them if necessary;
- diligently following up on reports received, relying on the individuals responsible for handling reports;
- providing a reply to the report within three months of the date of the acknowledgement of receipt or, in the absence of such an acknowledgement, within three months of the expiry of the seven-day period from the submission of the report.
THE EXTERNAL WHISTLEBLOWING CHANNEL (ANAC)
The whistleblower may make an external report using the channels specifically set up by ANAC — the Italian Anti-Corruption Authority — if, at the time of the report, one of the following conditions is met: the company's internal whistleblowing channel is not active or, if activate, it is not compliant with Italian Legislative Decree no. 24/2023; the whistleblower has already made an internal report and the report has not been followed up; the whistleblower has reasonable grounds to believe that, if they were to make an internal report, the report would not be effectively followed up or reporting might give rise to the risk of retaliation; the whistleblower has reasonable grounds to believe that the violation might constitute imminent or obvious danger to the public interest. See https://www.anticorruzione.it/-/whistleblowing
Personal data will be processed in accordance with the GDPR no. 679/2016 and Italian Legislative Decree no. 24/2023.