Whistleblowing

In compliance with Legislative Decree 24/2023, Beni Reali SpA has set up an internal reporting channel through which internal or external persons, linked to the company by work or business relations, can report, having become aware of it in the work context:

  • violations that harm the public interest or the integrity of the company Beni Reali S.p.A;
  • administrative, civil, criminal, tax and accounting offences;
  • violations of national or EU law: in particular offences related to the following areas (public contracts; services, products and financial markets and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental and occupational health and safety; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; privacy and personal data protection and security of networks and information systems);
  • acts or omissions affecting the EU’s financial interests (Article 325 TFEU fight against fraud and illegal activities affecting the EU’s financial interests) as identified in EU regulations, directives, decisions, recommendations and opinions (Art. 2, c. 1, lett. a), n. 4);
  • acts or omissions affecting the internal market, which compromise the free movement of goods, persons, services and capital (Art. 26, par. 2, TFEU). This includes violations of EU competition and state aid rules, corporate tax rules and mechanisms whose purpose is to obtain a tax advantage that frustrates the object or purpose of the applicable corporate tax law (Art. 2, c. 1, lett. a), n. 5);
  • acts or conduct that frustrate the object or purpose of EU provisions in the areas indicated in the preceding points. This includes, for example, abusive practices as defined by the case law of the Court of Justice of the European Union.

Disputes, claims or requests linked to a personal interest of the reporting person or of the person filing a complaint with the judicial or accounting authorities that relate exclusively to his or her individual employment relationships, or inherent to his or her employment relationships with hierarchically superior figures, may not be reported.

Reports must be circumstantiated, must relate to facts known and established directly by the whistleblower – and not reported by others – and, if possible, must identify with certainty the author of the unlawful conduct.

The report must be made by e-mail to be sent to whistleblowing@benireali.it or orally, by means of a face-to-face meeting set within a reasonable period of time to be requested, by the person making the report, by registered letter 1 with acknowledgement of receipt and proof of delivery to be sent with the wording “IN CONFIDENTIAL WAY” to the company’s whistleblowing officer – Avv. Marco De Paolis – Piazzetta Mons. Almici no. 13, 25124 Brescia.

The company’s whistleblowing officer ensures that the identity of the whistleblower is kept confidential.

The handling of reports is regulated by the procedure, which can be consulted in full at the following link, to which reference should be made. In any case, the confidentiality of the identity of the whistleblower and of the other persons indicated by Legislative Decree 24/2023 is guaranteed, to whom all the protections and limitations of liability provided for by the decree itself apply. Any kind of retaliatory act against them is prohibited”.

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