In transposition of Legislative Decree no. 24 of 10 March 2023, Neopharmed Gentili S.p.A. has endowed itself with the prescribed channels for receiving and managing reports called “whistleblowing”.
Who can report?
- Shareholders and persons with administrative, management, control, supervision or representation functions, even if these functions are exercised on a factual basis, at Neopharmed Gentili S.p.A.;
- Employees, trainees, self-employed workers, freelancers and consultants who works at Neopharmed Gentili S.p.A.;
- Individuals who have held the above roles in the past, if information about violations was acquired during the relationship, and individuals with whom the relationship has not yet arisen – for example, candidates for recruitment or employees during the trial period.
Areas of potential reporting
The list is very articulated and complex. For completeness, please refer to Legislative Decree 24/20231.
Reporting channels
Although these channels represent the preferred system for submitting reports, it is also possible to report through a face-to-face meeting with a professional external to the company, by making a request through one of the channels mentioned above.
Neopharmed Gentili S.p.A. guarantees the confidentiality of whistleblowers and prohibits any form of retaliation against them.
1 In general, are potentially subject to reporting violations of European Union regulations that harm the public interest or the integrity of the Company, of which the whistleblower has become aware in the work context, consisting of: significant unlawful conduct pursuant to Decree 231/2001 or violations of Model 231; offences falling within the scope of European Union or national acts or national acts implementing European Union acts in the field of public procurement; financial services, products and markets and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; protection of privacy and protection of personal data and security of network and information systems; acts or omissions affecting the financial interests of the European Union pursuant to art. 325 of the Treaty on the Functioning of the European Union; acts or omissions concerning the internal market, pursuant to art. 26(2) T.F.U.E. (including infringements of competition and State aid and corporate tax offences); acts or behaviour which, while not constituting an offence, defeats the object or purpose of the provisions contained in Union acts in the areas indicated above.
Significant unlawful conduct pursuant to Legislative Decree 231/2001 or violations of Model 231 adopted by the Company are also subject to possible reporting.
2 To protect the confidentiality of the Whistleblower, if the Whistleblower wishes not to give consent to the disclosure of his/her identity, written reports must be sent from personal, non-corporate e-mail accounts (therefore, it is necessary to avoid sending reports from accounts on the company domain). Any anonymous reports must be sent from e-mail accounts – if necessary, also created for the occasion – from whose address the identity of the Whistleblower cannot be deduced.
