Speak Up!

RGI, In compliance with EU Directive 2019/1937 of the European Parliament and of the Council and transposition laws of RGI Countries, has updated its whistleblowing system for the management of reports, including anonymous ones, which is valid in Italy and abroad and for all RGI Group companies.

RGI Group new whistleblowing system provides (i) a confidential channel to make reports, even anonymously, which is managed by a specialized third-party provider, (ii) as well as a new Speak Up! Group policy.

The violations which can be reported include:

Breaches of European Union law such as:

  • offenses falling within the scope of European Union or national acts specified in Directive (EU) 2019/1937 (hereinafter "EU Directive")
  • acts or omissions that harm the financial interests of the European Union, as well as those concerning the internal market, including violations of the European Union's competition and State aid rules
  • acts or conduct that frustrate the object or purpose of the provisions set forth in the acts of the European Union in the areas indicated in the preceding points

Conduct may be reported in violation of the Code of Conduct, internal regulations, Group policy and therefore the RGI Group Compliance Program or, in general, the Compliance Models of foreign subsidiaries (where adopted), however suitable to cause damage or prejudice, even only image, to the RGI Group.

As for Italy:

  • conducts or a situations contrary to 231 Model, the Code of Ethics, as well as regulations, directives, policies and internal procedures adopted by the Company and relevant under Legislative Decree 231/2001

As for Germany:

  • criminal offenses
  • violations that are subject to fines, insofar as they serve to protect life or health or to protect the rights of workers or their representative bodies
  • violations of federal and state laws
  • administrative offenses, if they may endanger life, limb, or health

As for France:

  • a crime or offense
  • a serious and manifest violation of an international commitment duly ratified or approved by France or of a unilateral act of an international organization adopted on the basis of that commitment
  • a serious and manifest violation of law or regulations
  • serious threat or prejudice to the general interest

Reports can be presented through an internal channel, dedicated to competent subjects individualized for region, namely:

The Competent Persons identified for Italy are:

  1. Speak Up! Italy Committee of RGI S.p.A. composed of:
    • Head of Group Compliance
    • Head of Legal
    • Group Academy Director
  2. Supervisory Board of RGI S.p.A

The Competent Subjects identified for France are:

  1.  Human Resources of Kapia RGI

The Competent Persons identified for Germany are:

  1.  Compliance Manager of Novum RGI
  2.  Compliance Manager of Flexperto

The Competent Persons identified for Tunisia are:

  1. Human Resources of RGI Tunisia

If one of the Competent Subjects is the subject of the Report and, therefore, Reported, the latter will not receive the Report, being automatically excluded from the internal computer reporting channel Speak Up! In this case the Report will be received only by the other Competent Subjects that are not Reported. In the event that the identified Competent Entity is only one, if it is Reported, the Report will automatically reach only the Head of Group Compliance.

For the use of the SpeakUp! Channel:

  1. Access the Speak Up! IT channel for each RGI Group company:
  2. Register with email, preferably personal, and password of your choice. The data required for the registration of the Whistleblower are not accessible to the RGI Group, as the IT channel for the Whistleblower is made available and managed by an external supplier
  3. After registering with the system, the Whistleblower will receive an email of registration, containing their credentials and a link to confirm the email address
  4. From the menu at the top left, the Whistleblower will be able to select the option “create a report” choosing between the written or oral form (voice recording)
  5. The Whistleblower may choose to create the Report anonymously (for details see paragraph 9 of this Policy)
  6. Once you have chosen the reporting mode, you will need to fill in all the fields marked as mandatory by the symbol *
  7. Indicate, if known, the type of infringement (as provided for in paragraph 4. 1. or select “other”)
  8. The Whistleblower may attach supporting documentation
  9. And, before submitting the Report, you will have access to a summary screen
  10. Finally, send the Report
  11. For assistance related to the tool write to: assistenza@mygovernance.it

The whistleblowing system also provides an external channel, with which Reports can be presented to the competent Public Authorities in case:

  • a report was already made and was not followed up
  • in case of well-founded reasons to believe that an internal report would not be effectively followed up/ may result in the risk of retaliation
  • well-founded reasons to believe that the report may bring an imminent or obvious danger to the public interest

Reports can also be reported via Public Disclosure in case:

  • the whistleblower has already made an Internal and External Report and has not received any feedback
  • the whistleblower has well-founded reason to believe that, due to the specific circumstances of the concrete case, the External Reporting may pose a risk of retaliation or may not be effectively followed up

The use of anonymous forms of Report, in which the identity of the Whistleblower is not made explicit or identifiable by the same, is permitted, as long as they are sufficiently circumstantiated and thus bear sufficient factual elements to initiate an investigation activity (e.g.: the offence committed, the reference period and possibly the value, the causes and purpose of the offence, the Company/function concerned, the persons/units involved and the anomaly on the control system).

Anonymous Report is carried out using the methods provided for internal reporting.

The guarantees provided by RGI Group whistleblowing system include:

  • prohibition of retorsion: no threat, retaliation, unjustified sanction, or discrimination against the Reporting Person, the Reported Person, and those who have cooperated in the feedback activities regarding the merits of the Report
  • confidentialiy obligation: no disclosure of information relating the reporting person, the reported person, the content of the report and other people involved in the reporting process

Reports having a mere defamatory, discriminatory, slanderous and/or vexatious nature, mere suspicious or rumors and complaints regarding personal situations are not permitted and if reported, will be archived


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