BTP Infrastrutture S.p.A. (“BTP INFRA”) has adopted a system for the reception, analysis, and management of reports of unlawful and irregular conduct (i.e. Whistleblowing), pursuant to the Legislative Decree of 10 March 2024 “Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council of October 23, 2019, on the protection of persons who report breaches of Union law and on provisions concerning the protection of persons who report breaches of national laws”. The management system for the reports is an integral part of the Organization, Management and Control Model under Legislative Decree No. 231/2001 ("Model").
What can you report?
You can report:
- Conduct which is deemed unlawful, pursuant to Legislative Decree No. 231/2001
- Violations of the Model, the Code of Ethics, and internal procedures, of which the reporter has become aware within the working environment of BTP Infrastrutture spa.
In particular, the reports only regard facts which have been witnessed directly by the reporter, and not based on word of mouth. The reports cannot regard grievances of a personal nature, personal demands, or retaliations. In any case, reports referring to conduct, crimes, or irregularities to the detriment of the Company are also to be considered relevant.
Who can report?
The following individuals can make reports:
- Shareholders and members of the administrative, management, control, supervisory or representative bodies of BTPINFRA (e.g., Shareholders' Meeting, Board of Directors, Board of Statutory Auditors, Supervisory Board, etc.) Even if they perform these functions on a mere de facto basis;
- Employees of BTPINFRA regardless of the type of contract envisaged and the classification and functional level held, including permanent and non-permanent employees, managers, executives, collaborators, interns, etc.;
- Self-employed workers and partnership holders who work at BTPINFRA;
- Clients, partners, suppliers of products or services (including contracting/subcontracting), freelancers, consultants, agents and intermediaries, who provide their services for BTPINFRA;
- Volunteers and the paid and unpaid interns who work at BTPINFRA.
What are the reporting channels?
Reports can be sent via https://btpits.whistlelink.com/, through which it is possible to access a safe and protected reporting system which permits you to easily report any possible violations, ensuring the confidentiality of the reporter. All information relevant to the reporting process and report management system can be found on the aforementioned site. It is possible to access the system at any time and through any device.
It is also possible to send oral reports via a voice messaging system available from the above system.
Upon the reporter’s written request, a meeting can be set up with the Reporting Manager.
Anonymous reports may be made, provided they are adequately substantiated and detailed.
Who is the Reporting Manager?
The Supervisory Board of BTPINFRA, as the Reporting Manager, receives the reports and carries out the relevant investigative activities, aimed at ascertaining whether or not the reported facts are true, with the help of internal resources.
What protection is afforded to the reporter?
The utmost confidentiality on the identity of the reporter and the subject of the report is guaranteed by the Reporting Officer and all persons who, in any capacity, become aware of the report or are involved in the process of ascertaining the facts that are the subject of the report.
No form of retaliation, direct or indirect, on the terms and conditions of employment for reasons directly or indirectly related to the Reporting shall be allowed or tolerated against the Reporting Party.
How is personal data processed?
For information regarding the processing of data relative to the reporting, please refer to the document “Informative data processing” in this page.