WHISTLEBLOWER POLICY
Reporting of wrongdoing and irregularities
This procedure governs the methods for reporting violations of national or European Union regulations pursuant to Legislative Decree 24/2023, which implements EU Directive 2019/1937 (Whistleblowing).
The procedure applies to Biodiversa S.r.l. (hereinafter the “Company”).
- Purpose of the procedure
Biodiversa S.r.l. promotes a corporate culture based on ethics, legality, and transparency, encouraging the reporting of illegal conduct or irregularities that become known in the workplace.
The procedure guarantees:
• confidentiality of the whistleblower's identity
protection from retaliation
• impartial handling of reports
- Who can make a report?
Anyone can make reports:
employees
employees and consultants
suppliers and partners
candidates and former employees
• interns and volunteers
• any subject that has professional dealings with the Company
- What violations can be reported
Violations of national or EU regulations that harm the public interest or the Company's integrity may be reported, including:
crimes against public administration
fraud and corruption
• violations of occupational safety regulations
environmental offenses
• data protection violations (GDPR)
- accounting or financial irregularities
• Violations of Legislative Decree 231 or internal procedures
- serious ethical misconduct
They are not included:
• personal disputes or interpersonal relationships
• Commercial complaints or customer requests
- Internal signaling channels
The Company provides the following channels.
Dedicated Email:
whistleblowing@biodiversa.it
(if it doesn't exist, activate it before publication)
Alternative PEC:
biodiversasrl@pecitaly.eu
Mailing address:
Biodiversa LLC.
Confidential Whistleblowing
Via Roma 31
31100 Treviso (TV) – Italy
Reports can be anonymous, but named reports make investigations easier.
- Content of the report
The report should include:
description of facts
Date and place of the event
• parties involved
• any documents or evidence
• Contact for any clarifications (optional)
Reports must be made in good faith.
- Report Management
Reports are handled by the person appointed by the Company.
Times provided for by Legislative Decree 24/2023:
• confirm receipt within 7 days
• feedback within 3 months
Additional information may be requested during the investigation.
- Confidentiality
Maximum confidentiality is guaranteed on:
• reporter's identity
• report content
• Identity of the people involved
Data is processed in compliance with GDPR and the Privacy Policy:
https://www.biodiversa.it/privacy-policy/
- Whistleblower Protection
Any form of retaliation is prohibited, including:
• dismissal or suspension
Demotion
Discrimination
• mobbing or harassment
Reputational damage
Retaliation is prohibited even if the report is not confirmed, as long as it is made in good faith.
- External reports
The whistleblower can directly contact ANAC when:
the internal channel is not active
fears retaliation
- internal reporting has not been followed up
ANAC Channel:
https://www.anticorruzione.it/-/whistleblowing
- Data conservation
Reports and documentation are kept for a maximum of 5 years from the closure of the proceedings.
- Whistleblower responsibilities
Anyone who makes false reports with intent or gross negligence may be subject to disciplinary and legal liability.
- Updates
This policy may be updated periodically. Changes will be posted on this page with the date indicated.
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