We’ve implemented a comprehensive system across 2i Rete Gas S.p.A. and our other group entities to gather and oversee reports regarding any misconduct within the company’s operations. This includes violations, through conduct, actions or omissions of national or European Union regulatory statutes that undermine public interest or the integrity of the entity, which have been brought to light by whistleblowers in a professional setting.
These reporting channels were recently aligned with the regulations outlined in Legislative Decree no. 24 of 10 March 2023 (hereinafter also referred to as “the Decree”), ratified in accordance with Directive (EU) 2019/1937. This adaptation reaffirms the authority of the Supervisory Bodies within the respective companies to oversee the processes for handling such reports. These procedures are comprehensively outlined in the Code of Ethics, an integral component of the Organisation, Management and Control model.
The internal reporting channels, in compliance with the regulations outlined in the Decree, have been meticulously crafted to ensure the utmost confidentiality regarding the identity of the whistleblower, individuals involved, and any parties mentioned in the report. Additionally, measures are in place to safeguard the confidentiality of the report’s content and associated documentation.
Below is a summary of the internal reporting channels implemented by type and reference company.
Internal reporting channels
TYPE
COMPANY
SPECIFIC REFERENCES
Dedicated telephone switchboard
A singular telephone number is designated for all Group companies, with an instruction prompting callers to specify the relevant company by entering alphanumeric keys following the initial voice message.
2i Rete Gas S.p.A.
2i Rete Gas S.p.A.- Code of Ethics Supervisory Body – Via Alberico Albricci, 10, 20122 Milan
2i Rete Dati S.r.l. – Code of Ethics Supervisory Body – Via Alberico Albricci, 10, 20122 Milan
Oral communication
At the request of the whistleblower to the Supervisory Body, by appointment to be set within a reasonable time
Type: Letter
Company: 2i Rete Gas S.p.A.
Specific references: 2i Rete Gas S.p.A.- Code of Ethics Supervisory Body – Via Alberico Albricci, 10, 20122 Milan
The 2i Rete Gas group, in compliance with the adjustments made in line with the provisions of the aforementioned Decree, has also revised, for both the parent company and its subsidiaries, the pertinent information as per Article 13 of EU Regulation 2016/679. This update aims to promptly describe the procedures for processing and storing the personal data of whistleblowers, as well as the personal data included in the reports.
External reporting channels
The whistleblower may submit an external report to the National Anti-Corruption Authority (A.N.A.C.) as per Article 7 of Legislative Decree no. 24/2023 if, at the time of submission, one of the conditions provided below (outlined in Article 6 “Conditions for submitting an external report” of the Decree), is met.
a) If there is no requirement within the work context to activate the internal reporting channel, or if this channel, even if obligatory, is not operational, or even if activated, does not adhere to the stipulations of Article 4.
b) the whistleblower has already made an internal report as per article 4 and it has not been followed up;
c) the whistleblower has reasonable grounds to believe that, if an internal report was submitted, it would not be effectively followed up or that the same report could determine the risk of retaliation;
d) the whistleblower has reasons for believing that the breach may constitute an imminent or clear threat to public interest.
The channels and procedures governing external reporting are those provided for in Article 6 and the following Articles up to Article 14 of Legislative Decree n.24/2023.
2i Rete Gas S.p.A. and Group company employees must submit an internal report before submitting an external report.