The “Whistleblowing” Violation Reporting System
Solution Bank S.p.A. has adopted an internal system to enable the reporting of alleged violations of national and European Union regulatory provisions as well as the principles contained in the Organization and Management Model adopted pursuant to Legislative Decree 231/2001.
Who can make a report
Possono effettuare una segnalazione:
- employees (this possibility is also recognized (i) when the legal relationship has not yet begun, if the information on violations was acquired during the selection process or other pre-contractual stages or during the probationary period, (ii) after the dissolution of the legal relationship if the information on violations was acquired during the course of the relationship) and self-employed workers;
- holders of a professional collaboration relationship referred to in Article 409 c.p.c. (e.g., agency relationship) and Article 2 Legislative Decree 81/15 (collaborations organized by the principal);
- Workers or collaborators who provide goods or services or perform works for third parties;
- freelancers and consultants;
- volunteers and interns (paid and unpaid);
- shareholders (individuals);
- Persons with administrative, control, supervisory or representative functions.
For the purpose of reporting, the above legal relationships must be with Solution Bank S.p.A.
How to make a report/strong>
Solution Bank S.p.A. has provided a reporting channel that electronically guarantees the confidentiality of the reporter’s identity.
The platform allows reporting in written or oral form.
Access to the platform for entering reports must be made using the links below:
User manuals for the computer platform are made available to users.
The report must allow for the identification of the reporter, where required by the regulations, and must contain a detailed description of the facts and conduct considered to be contrary to the regulations, also indicating, where possible, the documents, rules that are considered to have been violated, and other findings useful for conducting the investigation into the facts alleged. Finally, the reporter is required to declare whether he or she has a personal interest related to the report.
The channel does not provide for the filing of complaints and grievances of a personal nature.
The information acquired will be treated with the utmost care and absolute confidentiality.
The 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 the relevant management, in fulfillment of a legal obligation. The data will be kept no longer than 5 years of the final outcome of the procedure.
Channels external to Solution Bank S.p.A.
As a priority, reporting persons are encouraged to use internal channels and, under certain conditions, may make an external report directly to the relevant authorities.
It is possible to make an external report, for Italy, to the National Anticorruption Authority (ANAC), if one of the following conditions is met at the time of its submission:
- there is no provision within the work environment for mandatory activation of the internal reporting channel, or it is not active or, even if activated, does not comply with external regulations;
- has already made an internal report and the report has not been followed up, where follow-up means the action taken by the person entrusted with the management of the reporting channel to assess the existence of the reported facts, the outcome of the investigation and any measures taken;
- has reasonable grounds to believe that if it made an internal report, the report would not be effectively followed up or that the report itself could result in the risk of retaliation;
- has probable cause to believe that the violation may constitute an imminent or obvious danger to the public interest.
The reporting person may also turn to ANAC to notify any retaliatory acts suffered as a result of a report.
External reports to the ANAC can be made in the manner provided on the institutional website of the Entity.