In conformity with the provisions of Legislative Decree 24/2023 implementing EU Directive 2019/1937, through the Orbyta Group Whistleblowing Channel it will be possible to report conduct, acts or omissions that harm the public interest or integrity of one of the Orbyta Group companies.

Questions and Answers:

Who can submit a report?

The following can make a report:

employees, self-employed persons, partnership holders, and interns, including unpaid interns, who work for one of the Orbyta Group companies;

freelancers, consultants and collaborators in any capacity who work at one of the Orbyta Group companies;

in general, anyone who comes into contact, for any reason, with one of the Orbyta Group companies.

What to report?

Reports must concern facts of which the reporter has knowledge and must be made promptly with respect to the knowledge of the facts so that timely action can be taken.

In particular, the following may be reported:

illegal or suspicious conduct, administrative, accounting, civil or criminal offenses;

irregularities in corporate activities;

acts or facts that may constitute a violation of the rules, internal and external, that govern the activities of the Orbyta Group or that violate the principles and rules of conduct contained in the Code of Ethics;

offenses that fall within the scope of application of European Union or national acts relating to the following areas: public procurement; services, products and financial markets and prevention of money laundering and financing of terrorism; product safety and compliance; transportation safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; privacy and personal data protection; and network and information system security;

acts or omissions affecting the financial interests of the European Union;

acts or omissions concerning the internal market;

acts or conduct that frustrate the object or purpose of the provisions set forth in the acts of the European Union.

What cannot be reported?

The following may not be reported: disputes, claims or requests related to interests of a personal nature that pertain exclusively to the employment relationship or inherent in the relationship with hierarchically subordinate figures; communications or complaints related to activities of a commercial nature or services to the public.

Should the whistleblower make untruthful or defamatory reports – without prejudice to the criminal and civil liability of the whistleblower – the whistleblower may be subject to the application of a disciplinary sanction ranging from €500 to €2,500.

How is the confidentiality of the reporter guaranteed and who handles the report?

The Orbyta Group guarantees the absolute confidentiality of the identity of the reporter and the content of the report, with secure protocols and encryption tools. The identity of the whistleblower is never disclosed without the whistleblower’s consent, except in cases stipulated by the applicable regulations.

Whistleblowing is handled by a special Whistleblowing Committee composed of individuals who – in accordance with the principles of impartiality, confidentiality and data protection – have autonomy and independence.