The Company, in accordance with the applicable regulations, provides free access to a dedicated on-line portal (Whistleblowing Portal) to those who intend to submit, in good faith, reports on unlawful conducts, misconducts or omissions, that constitute or may constitute a violation, or inducing to a violation, of the Code of Ethics, of the Model of Organization, Management and Control pursuant to Legislative Decree no. 231/01 adopted by the Company and its implementation documentation (e.g. Group policies and Company rules).
Reports are accepted also anonymously. The Company will prosecute Whistleblowers in case of Reports made in bad faith, with defamatory intent or not intended to be in line with a proper spirit of cooperation with the Company. Reports must be submitted to protect the integrity of the Company and must be detailed, based on precise and concordant fact-checking elements. Reports must be submitted responsibly, with the aim of pursuing common good and fall under the kind of non-conformities prescribed by the system in place. The Company recommend not to submit Reports for issues different from the ones abovementioned and, as a general prescription, suggest employees to solve conflicts, whenever possible, through communication, even informally, amongst colleagues and/or with the direct supervisor or the competent Functions within the Company.
WAYS OF SENDING REPORTS
Reports can be sent:
It should be noted that the paper form, by regular mail, and the Whistleblowing Portal are the best ways aimed at fully guaranteeing the possible anonymity of the Whistleblower.
The access to the Whistleblowing Portal is in fact subject to the “no-log” policy in order to prevent the identification of the Whistleblower who wishes to remain anonymous: this means that the company's computer systems are not able to identify the access point (IP address) even if you are logged in from a computer connected to your corporate network.
For each Report submitted, the Portal assigns a unique identification code that allows each Whistleblower to check its progress, anonymously. Similarly, if a Report is not adequately detailed, the recipients have the right to request the Whistleblower, using the Portal and always through that code, further details of what is reported.
Reports made through the Whistleblowing Portal are received by the Company's Supervisory Body and by the Head of Corporate Internal Audit of the Mapei Group; the latters handle the Report in accordance with confidentiality principles set out in this Policy and verify its validity in accordance with its content.
WHISTLEBLOWER’S PROTECTION AND RESPONSABILITY
No retaliation, discrimination or penalty, direct or indirect, will affect those who have made a Report in good faith. In the case of Reports made through the Whistleblowing Portal, the anonymity of the Whistleblower is guaranteed, except in cases where the Whistleblower expresses his consent to disclose and without prejudice to legal obligations. There are also penalties for those who violate the Whistleblower's protection measures.
There are penalties against the Whistleblower, whenever possible, in case of Reports made with willful intent or gross negligence that are false, baseless, with defamatory content or otherwise made for the sole purpose of harming the Company, the Reported or the ones affected by the Report. The Company may also take proper legal actions.
THE REPORTED’S RIGHTS
During the investigation and the verification of possible non-compliance, individuals who are the subject of the Reports may be involved or notified of this activity, but under no circumstances a procedure will be initiated solely based on the Report, in the absence of concrete evidence on its content. This could possibly be done on the basis of other evidence found and established from the Report itself.
PRIVACY AND DATA PROTECTION
Any personal and sensitive information contained in the Report, including those relating to the identity of the Whistleblower or other individuals, will be processed in accordance with the applicable rules for the protection of personal data.
