Whistleblowing

WHISTLEBLOWING POLICY

While the term whistleblowing refers to the process by which those who come into contact with the company can confidentially report violations of the law, the term whistleblowers refers to the persons who report them.

In Italy, the subject of whistleblowing is regulated by Legislative Decree No. 24 of 10 March 2023, the ANAC guidelines and the Confindustria Operating Guide.

In the private sector, the rules on whistleblowing apply to companies that have employed an average of 50 subordinate workers in the last year, that have adopted an organisation, management and control model, or that deal with services, products, financial markets, prevention of money laundering, prevention of terrorism financing, transport safety and environmental protection.

Intending to operate in absolute compliance with the laws and regulations in force, the company X2 Solutions s.r.l. encourages all its stakeholders to promptly report any conduct, commission/omission, that marks/can mark a violation of the law.

On this basis, the company X2 Solutions s.r.l. has adopted an IT platform for receiving and managing whistleblowing reports, which can be reached at https://scswhistleblowing.com/x2solutions/form, designed to guarantee the confidentiality of the reporting persons, reports and related documentation by means of End-to-End (E2E) encryption.

Said platform, developed in compliance with the provisions of Legislative Decree No. 24 of 10 March 2023, Regulation (EU) 2016/679 and Legislative Decree No. 196 of 30 June 2003, will enable the reporting person to formalise the whistleblowing report in writing, by means of a voice messaging system, or at a direct meeting with the manager identified by the Organisational Act adopted on 13 December 2023 by the administrative body, and for the latter to properly take care of all legal requirements, providing timely feedback on the whistleblowing report.

Please note that, in the event that the manager identified by the Organisational Act adopted on 13 December 2023 by the administrative body coincides with the person reporting the whistleblowing, the whistleblowing report may be addressed to the head of the Human Resources corporate function, by registered mail with return receipt, to the address X2 Solutions s.r.l. – To the kind attention of the head of the Human Resources corporate function – Via XXI Luglio 1969, 2 – 41037 Mirandola (MO).

Please also note that the reporting person who acts in good faith is recognised ex lege the protection of confidentiality, protection against possible retaliation, as well as important limitations of liability.

Finally, it should be noted that it is recognised by law that the reporting person has the right to formalise the whistleblowing report by addressing it directly to the ANAC and that this right may be exercised if the manager identified by the Organisational Act adopted on 13 December 2023 by the administrative body has not acted diligently on the whistleblowing report, or if there are reasonable grounds to believe that the whistleblowing report may not be acted upon diligently, or may cause retaliation.

For more information click here (Whistleblowing – Organisational Document).

For information on the processing of personal data click here (Whistleblowing – Information on the processing of personal data with regard to whistleblowing reports).