In addition to OCTO’s Code of Ethics and Anti-Corruption Policy, OCTO has adopted a Whistleblowing Policy with the aim of strengthening the Corporate Governance system within the organization, including measures to prevent actions or omissions that:
• are not in line with OCTO’s values and Code of Ethics, the Anti-Corruption Policy, and, in general, the compliance procedures adopted by the organization; and/or
• are not compliant with applicable laws; and/or
• could significantly harm OCTO’s interests.
This Policy outlines how to report concerns related to unlawful or unethical conduct connected to OCTO’s activities and business relationships.
In compliance with Octo’s Organisational, Management and Control Model, pursuant to Italian Legislative Decree. n. 231 of 2001, and internal anti-corruption regulations, we have adopted a system for the management of whistleblowing reports that enables us to manage whistleblowing reports received, including anonymously.
We guarantee the management, analysis and handling of whistleblowing reports that are sent by or transmitted form anyone, stakeholders, Octo’s People or other third parties, also when confidential or anonymous. We consider a “whistleblowing report” any communications concerning behaviours that relate to Octo’s People in violation of the Code of Ethics, any laws regulations, provisions of authorities, internal regulations, 231 Model that may cause damage or prejudice to Octo.
These include cases of fraud, against the company assets and/or in financial reporting, illegitimate behaviour pursuant to Italian Legislative Decree. n. 231 of 2001, Code of Ethics violations, possible corruptions, or violations of anti-corruption regulatory instruments. Investigation are carried out by the Whistleblowing Committee on the reported facts and results are presented to internal inter-functional bodies dedicated to managing whistleblowing reports, the Board of Statutory Auditors and the 231 Supervisory Board.
The identity of whistleblowers must always be kept confidential, and whistleblowers should not face any liability whether civil, criminal, administrative, or employment-related if they report a violation in good faith through the communication channels made available.
At the same time, OCTO intends to act promptly against anyone who, with malice or gross negligence, submits reports of violations that turn out to be non-existent.
Our Whistleblowing Policy complies with the provisions of Legislative Decree No. 24/2023, which implements EU Directive 2019/1937 in Italy, concerning the protection of individuals reporting breaches of Union law, and includes provisions for the protection of individuals reporting breaches of national legal provisions.
