TTozzi Green has decided to join the Business Integrity Forum promoted by Transparency International Italia and therefore has adopted the Charter of Ethical Principles for small and medium-sized companies.
“The Charter of Ethical Principles is the voluntary declaration of the company, which subscribes to these principles in its business practice in order to contribute to the creation of an atmosphere of transparency, integrity and trust for the activities carried out within and outside its organisation.”
Tozzi Green has set up a whistleblowing system, as part of its internal control activities for the purpose of preventing offences, which can be used by employees, collaborators of various kinds, business partners and suppliers in order to report situations, requests or schemes not in line with the principles laid down in the Code of Ethics and the Charter of Ethical Principles.
Reports, which are handled as described further below, should be sent to:
firstname.lastname@example.org – email@example.com
What is the aim of the procedure? What can be reported?
Reportable conduct includes everything which constitutes or could constitute possible violations of law, internal company regulations and procedures, including violations of the code of ethics (such as offers of money or other benefits in order to obtain appointments, job orders, licences or permits, illicit pressure to speed up the issue of documents, repeated violations of safety and environmental protection procedures, access of unidentified personnel to production sites,…)
What kind of information must a report contain?
A report, even if anonymous, is not like a report to the police and must be described sufficiently in detail and based on evidence acquired first hand in order to make an adequate response possible.
Who are the reports sent to?
The members of the supervisory Body set up in accordance with Italian legislative decree 231/2001 who handle the report in a confidential and secure way.
What are the duties of those who received the report?
The person who receives the report will proceed with an initial screening in terms of admissibility and, if it passes this stage, will initiate an internal inquiry with the possibility of consulting other company structures but in any case maintaining the identity of the reporting person confidential. The person receiving the report will write up his/her own report on the matter and pass it on to the Board of Directors for any internal measures.
During the procedure the whistleblower will receive some feedback.
Is it possible to report anonymously?
Yes, if the report gives as much detail as possible (they cannot be considered if precise information is not provided).
In what way is the whistleblower protected?
First of all any persons reported and third parties will not have access to the identity of the whistleblower. The necessary actions and measures will be taken against anyone who attempts or threatens to take retaliatory action against the whistleblower.
What protection is afforded the person who has been reported?
No disciplinary action will be taken against the person reported solely on the basis of the report but only if the report has been confirmed internally.
Can the procedure involve penalties?
Penalties are provided in the case of:
– those who misuse the procedure with deliberately defamatory information;
– the person receiving the report does not take adequate action to verify the claims made in the report;
– any other persons who refuse to cooperate with the person receiving the report designated to verify the content of the report;
– those who attempt or threaten retaliatory action against the whistleblower.
Download the Report Format here