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Whistleblowing
Complaint reporting and handling procedure
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Whistleblowing – Procedure for reporting and handling complaints
This channel allows you to report, confidentially or anonymously, any illegal conduct, violations of regulations, company procedures or unethical behaviour that has come to light in the workplace or in relation to the activities of Rimsa P. Longoni S.r.l.
It is available to employees, collaborators, interns, candidates, suppliers, partners, consultants and other stakeholders who come into contact with the organisation.
Reports are handled using technical and organisational measures designed to ensure security, confidentiality, personal data protection and protection from retaliation.
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When we accept a report (eligibility criteria)
The report is taken into consideration when:
- it concerns facts, conduct or omissions that are potentially unlawful or contrary to internal rules, procedures or the Code of Ethics;
- it is related to the working environment or professional relationships with Rimsa;
- it contains sufficiently detailed information (who/what/where/when, as far as known) to allow for verification;
- it is submitted in good faith, based on information believed to be reasonably true at the time of reporting.
The following do not fall within the scope of this channel:
- customer service requests or commercial complaints (to be addressed to the dedicated channels);
- reports that are manifestly unfounded, offensive or deliberately false/defamatory (which may result in disciplinary or legal consequences).
If the report is not admissible or does not fall within the scope of whistleblowing, it will (where possible) be directed to the correct channel, protecting confidentiality and personal data.
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Process stages and management times
Phase A – Receipt and registration
- The report is recorded in the system with a case number.
- Within 7 days of submission, a confirmation of receipt is sent (unless otherwise requested by the reporting person or in cases where this could compromise their protection).
Phase B – Preliminary assessment
- Verification of eligibility and scope, urgency and priority, and activation (if necessary) of immediate measures to protect and safeguard evidence.
Phase C – Preliminary investigation
- Collection of information and documents, any requests for additional information, hearings where necessary.
- During the preliminary investigation phase, internal departments and/or external consultants may be involved only if necessary and always bound by confidentiality, with access to information according to the “need to know” principle.
Phase D – Feedback
- Within three months of confirmation of receipt (or, failing that, within seven days), feedback will be provided on the status and/or outcome of the investigation, within the limits permitted by law and the protection of third parties.
Phase E – Closure and corrective actions
- If the report is found to be justified, corrective measures (organisational, procedural, disciplinary, training) and a follow-up plan are defined, with responsibilities and deadlines.
- The case is closed with tracking of the outcome and actions taken.
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How we facilitate resolution
To ensure effective management and resolution of the reported problem, we adopt the following measures:
- secure communication channel with the reporting person (including anonymously, when technically possible) for requests for clarification or additional information;
- definition of corrective actions with responsible parties and timelines;
- immediate risk mitigation measures when necessary;
- “minimal” updates to the reporting person, consistent with confidentiality and the investigation.
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Protection from retaliation and stakeholder protection
Rimsa does not tolerate any retaliation against those who report in good faith or cooperate with the investigation.
The following are prohibited, by way of example:
- dismissal, suspension, demotion, punitive transfers;
- economic or career penalties;
- intimidation, pressure, discrimination, ostracism;
- indirect retaliation against colleagues or related parties.
Protective measures
- assessment of the risk of retaliation and, where appropriate, implementation of protective measures;
- confidential management of information flows and document segregation;
- possibility to immediately report any suspected retaliation through this same channel.
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Confidentiality, technical measures and channel security controls
To protect the identity of the reporting person (if not anonymous), the content of the report and the individuals involved, we adopt measures such as:
- access to content limited to authorised individuals only;
- access tracking and role management with minimum privileges;
- data protection through appropriate technical and organisational measures (e.g. encryption, segregation, secure backups, credential control);
- configurations designed to reduce the risk of indirect identification (e.g. data minimisation, log management, privacy by design and by default principles).
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Privacy and personal data protection (summary information)
The personal data provided in the report is processed for the following purposes:
- to receive and manage the report,
- to carry out checks and investigations,
- to take any corrective measures,
- to comply with legal obligations.
Minimisation: please only enter relevant and necessary information.
Access to data: limited to authorised persons bound by confidentiality.
Storage: data and documentation related to the report are stored for the time strictly necessary for the management and resolution of the case and, in any case, in accordance with the terms set out in the applicable legislation and internal storage policies.
Rights: the exercise of privacy rights may be subject to limitations in cases provided for by law, when necessary to protect confidentiality, investigations and the rights of third parties.
The complete privacy policy is available in the dedicated section of the company website and/or within the reporting system.
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Roles and responsibilities (Committee and independence)
The management of reports is entrusted to the company’s Whistleblowing Committee, consisting of the board of directors and the Whistleblowing manager, established to ensure competence, confidentiality and the absence of conflicts of interest.
A Complaints/Reports Management Officer is appointed within the Committee, who:
- coordinates the receipt, tracking, investigation and response to complaints;
- ensures that access to information is limited and documented;
- verifies that there are no conflicts of interest in the cases assigned.
Independence
Upon accepting the position and appointment, the Complaints/Reports Manager formally declared and swore to their independence, committing to operate with impartiality, confidentiality and independent judgement.
Management of conflicts of interest (binding rule)
If a potential conflict of interest (even if only apparent) arises in relation to a specific report:
- the case is immediately reassigned to another suitable member of the Committee or
- it is entrusted, where necessary, to an independent external party. The reassignment and the reasons for it are documented in the case file.
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Monitoring, tracking and annual summary
Each report is recorded in a confidential register with:
- file number, date of receipt, category, progress status;
- timelines (receipt/response/closure);
- outcome (substantiated/unsubstantiated/not assessable) and actions taken.
Transparency and reporting
On an annual basis, Rimsa publishes an aggregate summary (anonymous and without identifying data) on the status and subject matter of the reports received, including the main areas and corrective/preventive actions taken.
If no reports have been received, a statement confirming the absence of reports in the reference year is published.
This information is made available in the Annual Report on the Pursuit of Common Benefit, published and available on the company website.
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Alternative channels and external reporting
It is preferable to use the internal channel first. However, the legislation also provides for external reporting channels and additional safeguards in accordance with the conditions and procedures established by law. Al sine informs you of the possibility of reporting on the ANAC website.
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Practical note for those reporting
Before sending, please check the information you have entered. By sending the report, you confirm that the information provided is true and accurate to the best of your knowledge. Even in the event of an error made in good faith, the protections against retaliation remain in place.