Who Can Make a Report
Reports can be made by:
- Employees (this possibility is also recognized if i) the legal relationship has not yet begun, if the information about the violations was acquired during the selection process or other pre-contractual phases, or during the probationary period, ii) after the dissolution of the legal relationship if the information about the violations was acquired during the relationship itself) and self-employed workers;
- Holders of a professional collaboration relationship pursuant to Article 409 of the Civil Procedure Code (e.g., agency relationships) and Article 2 of Legislative Decree 81/15 (collaborations organized by the client);
- Workers or collaborators who provide goods or services or perform work on behalf of third parties;
- Freelancers and consultants;
- Volunteers and interns (paid and unpaid);
- Shareholders (natural persons);
- Individuals with administrative, control, supervisory, or representation functions.
For reporting purposes, the above legal relationships must be maintained with Solution Bank S.p.A.
How to Make a Report
Solution Bank S.p.A. has provided a reporting channel that ensures the confidentiality of the Whistleblower’s identity through electronic means.
The platform allows reporting in written or oral form.
Access to the platform for submitting reports must be done using the following links:
User manuals for the platform are available.
The report should enable the identification of the whistleblower, where required by law, and must contain a detailed description of the facts and behaviors considered to be in violation of the regulations, including, where possible, documents, rules deemed violated, and other useful evidence for the investigation of the reported facts. The whistleblower is also required to declare if they have a personal interest related to the report. The channel does not allow for the submission of personal complaints or grievances. The information acquired will be handled with the utmost care and absolute confidentiality.
Personal data and information acquired by Solution Bank S.p.A., to which the report is sent, will be processed by it as the Data Controller for management purposes, in compliance with legal obligations. Data will be retained for no more than 5 years from the final outcome of the procedure.
External Channels to Solution Bank S.p.A.
As a priority, whistleblowers are encouraged to use internal channels and, under certain conditions, may make an external report directly to the competent Authorities.
In Italy, an external report can be made to the National Anti-Corruption Authority (ANAC) if, at the time of submission, one of the following conditions is met:
- The mandatory activation of the internal reporting channel is not foreseen in the work context, or it is not active or, even if activated, does not comply with external regulations;
- An internal report has already been made and it has not been followed up, where follow-up means the action taken by the subject responsible for managing the reporting channel to evaluate the existence of the reported facts, the outcome of investigations, and any measures taken;
- There are well-founded reasons to believe that an internal report would not receive effective follow-up or that the same report might lead to the risk of retaliation;
- There are well-founded reasons to believe that the violation might pose an imminent or obvious danger to public interest.
The whistleblower may also contact ANAC to report any retaliatory acts suffered as a result of the report.
External reports to ANAC can be made according to the procedures outlined on the institution’s official website.
