Introduction

This Whistleblowing Procedure applies to BTO S.p.A., part of the Relatech Group, which has adopted an internal reporting system compliant with Legislative Decree no. 24 of 10 March 2023.

Regulations – Legislative Decree 24/2023

The whistleblowing legislation, introduced in implementation of Directive (EU) 2019/1937 and transposed into Italian law by Legislative Decree no. 24 of 10 March 2023, aims to facilitate the emergence of violations of national or European Union laws learned in the work context, while ensuring the protection of persons making reports and protecting them from any retaliation resulting from such reports.

 

What is Whistleblowing?

Whistleblowing is a term that refers to the reporting of information concerning violations falling within the scope of Legislative Decree 24/2023 of which a person has become aware in the work context. The whistleblowing system allows the persons identified by Legislative Decree 24/2023 to report such violations through dedicated channels that guarantee the confidentiality of the whistleblower's identity and protection against any retaliation.

 

What violations can be reported

Reportable violations are breaches of national or European Union laws that harm the public interest or the integrity of the public administration or private entity, of which the whistleblower has become aware in the work context (for example, environmental protection, public health, consumer protection, protection of privacy and personal data, etc.).

The following are expressly excluded from the scope of this procedure:

• complaints / claims / requests related to the whistleblower's personal interest concerning exclusively his or her individual employment relationship or employment position, or concerning his or her relations with hierarchical superiors;
• reports of violations already governed by specific European Union or national provisions that provide for dedicated reporting channels;
• reports of violations concerning national security.

 

Who can report

The following persons may make a report:

• employees of public administrations and public economic entities;
• private-sector employees;
• self-employed workers;
• collaborators, freelancers and consultants;
• volunteers and trainees, whether paid or unpaid;
• shareholders and persons with functions of administration, management, control, supervision or representation.

The protections provided by Legislative Decree 24/2023 also apply where information concerning violations is acquired during the recruitment process, during the probationary period or after termination of the employment or collaboration relationship, in the cases provided for by law.

 

How to report

Reportable violations may be reported through the INTERNAL channels established by BTO, which are designed to guarantee, as required by law, the confidentiality of the whistleblower's identity and of the information transmitted.

Pursuant to ANAC Guidelines no. 1/2025, ordinary email (PEO) and certified email (PEC) do not, as a rule, constitute suitable means for processing particularly sensitive data, especially when using accounts made available by the entity.

For this purpose, BTO has established the following secure INTERNAL channels:

• for reporting in written form, the platform available at https://my.studioziveri.it/CheckPage.aspx?guid=004d60bb-dc19-43cd-adc8-3017bad1a4e
• for reporting in oral form, by calling 02 45449711. Recording is subject to the whistleblower's prior consent. In the absence of consent to recording, the channel manager prepares a detailed report of the disclosure;

In addition, the whistleblower may request a direct meeting with the channel manager, to be held in a suitable place, including outside the entity, within a reasonable period.

The meeting is documented by means of minutes, which the whistleblower has the right to verify, amend and sign.

The management of BTO's internal channels has been entrusted to the company's Supervisory Body.

The platform made available by the provider (Studio Ziveri) allows reports to be made anonymously. Although access requires registration of an account, the identity of the whistleblower is not disclosed to the channel manager and may be communicated only in the cases and in the manner provided for by law or at the request of the competent Authority. Anonymous reports will be taken into consideration if they are sufficiently substantiated and allow the necessary checks to be carried out.

The whistleblower must, in any event, make the report in good faith and on the basis of information reasonably believed to be truthful at the time of reporting.

 

External channel (ANAC)

The whistleblower may alternatively decide to use the EXTERNAL channel set up by ANAC, available at https://www.anticorruzione.it/-/whistleblowing, in the following cases:

• the internal channels are unavailable or have not been activated;
• a report has already been made through the internal channel without any follow-up having been provided;
• the whistleblower fears that use of the internal channel would still expose him or her to retaliation;
• the whistleblower believes that the violation constitutes an imminent danger to the public interest.

 

Management of the report

The channel manager provides the whistleblower with an acknowledgement of receipt of the report within seven days of its receipt and provides feedback on the outcome of the report within three months from the date of the acknowledgement of receipt or, in the absence thereof, from the expiry of the seven-day period, without prejudice to cases in which the nature or complexity of the report requires additional time within the limits permitted by law.

 

Confidentiality

The identity of the whistleblower, the person involved (the so-called reported person), any persons mentioned in the report and the so-called facilitators, as well as the content of the report, are processed in compliance with the confidentiality obligations provided for by Legislative Decree 24/2023 and by legislation on the protection of personal data.

 

Sanctions

Pursuant to Article 21 of Legislative Decree 24/2023, ANAC may impose administrative fines ranging from Euro 10,000 to Euro 50,000 on the persons responsible, including in cases of retaliation, obstruction of reporting, breach of the confidentiality obligation, failure to establish a reporting channel, failure to adopt compliant procedures or failure to manage the report.

Where the whistleblower's liability for the offences of slander or defamation, or his or her civil liability for wilful misconduct or gross negligence, is established, including by a first-instance judgment, the protections provided by Legislative Decree 24/2023 cease to apply and ANAC may impose an administrative fine ranging from Euro 500 to Euro 2,500.

Consult the documents relating to BTO Research Whistleblowing:
Privacy Policy