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Whistleblowing

WHISTLEBLOWING POLICY 

While the term whistleblowing refers to the process through which those who come into contact with a company can confidentially report legal violations, the term whistleblowers refers to the reporting individuals.

In Italy, the subject of whistleblowing is regulated by Legislative Decree No. 24 of March 10, 2023, by ANAC guidelines, and by the Confindustria Operational Guide. In the private sector, the whistleblowing regulation applies to companies that have employed, in the last year, an average of 50 subordinate employees, that have adopted an organization, management, and control model, or that deal with financial services, products, and markets, prevention of money laundering, prevention of terrorism financing, transport safety, and environmental protection. Intending to operate in full compliance with current laws and regulations, the company Abraham Industries SRL encourages all its stakeholders to promptly report any conduct, whether commissive or omissive, that constitutes or may constitute a violation of law.

On these grounds, the company Abraham Industries srl has adopted an IT platform for receiving and managing whistleblowing reports, accessible at: https://scswhistleblowing.com/abrahamindustries/form, designed to ensure the confidentiality of reporting individuals, reports, and related documentation through End-to-End (E2E) encryption. This platform, developed in accordance with the provisions of Legislative Decree No. 24 of March 10, 2023, Regulation (EU) 2016/679, and Legislative Decree No. 196 of June 30, 2003, will allow the reporting person to formalize the whistleblowing report in writing, via voice messaging system, or during a direct meeting with the manager identified by an organizational act adopted, as per the sole director's determination of 16.12.2023, and will allow the latter to correctly handle all legal requirements, providing timely feedback on the whistleblowing report.

It should be noted that, in the event that the manager identified by the Organizational Act adopted, as per the sole director's determination of 16.12.2023, coincides with the reporting person/reported person, the whistleblowing report may be addressed to the head of the Human Resources corporate function, by registered letter with acknowledgment of receipt, to the address Abraham Industries srl – For the attention of the head of the Human Resources corporate function – Via Fosse incrociate, 284 – 4782 Santarcangelo di Romagna (RN). Furthermore, it should be noted that the reporting person acting in good faith is legally granted protection of confidentiality, protection against any retaliation, as well as significant limitations of liability.

Finally, it should be noted that the reporting person is legally granted the right to formalize the whistleblowing report by addressing it directly to ANAC, and that this right may be exercised if the manager identified by the Organizational Act adopted, as per the sole director's determination of 16.12.2023, has not diligently followed up on the whistleblowing report, or if there are well-founded reasons to believe that it may not be diligently followed up on/it may cause retaliation.