Internal Alert Procedure of the Sella group companies
The “Internal Alert Procedure” (also known as “whistleblowing”) is a tool for preventing and correcting acts or events that may constitute unlawful conduct under external and internal regulations (such as the Code of Conduct or the Code of Self-Discipline), harmful to the public interest or the integrity of the private entity. It promotes and protects the positive behavior of staff or other legitimate individuals identified by the regulations, who, upon becoming aware of the unlawfulness or illegitimacy of another person’s actions in the workplace, decide to confidentially report such acts or events to the designated authorities.
An effective whistleblowing system represents an important tool for the Sella Group in maintaining continuous compliance with transparency and integrity standards in its actions, as well as a useful warning signal that allows for the adoption of appropriate measures.
Who can submit reports
Reports can be submitted to the internal alert procedure by employees and by those who work in any capacity based on relationships that involve their inclusion or connection with the company organization, even in a form different from an employment relationship, such as:
- Self-employed workers, external workers and collaborators, freelancers and consultants who carry out their work at the Group;
- Paid and unpaid volunteers and interns;
- Shareholders and people with administrative, management, control, supervisory or representative functions;
- Staff of suppliers external to the Group.
What may be reported
Reports may concern any act or fact that may constitute a violation of the external rules governing the activity undertaken (banking activities pursuant to the Consolidated Banking Act (TUB) and the provision of investment services in accordance with the Consolidated Law on Finance, as well as those relating to the distribution of insurance products), and of the Group’s internal rules. Le segnalazioni possono, inoltre, riguardare gli illeciti previsti dal d.lgs 24/2023 (quali ad esempio la tutela dell’ambiente, appalti pubblici, la tutela della vita privata, la protezione dei dati personali, la sicurezza delle reti e dei sistemi informativi etc.), violazioni, potenziali o effettive, delle disposizioni dettate in funzione di prevenzione del riciclaggio e del finanziamento del terrorismo come previsto dall’art. Article 48 of Legislative Decree 231/2007, any other unlawful conduct under Legislative Decree 231/01, and any breach of the organisational model adopted by the Company. The report may also concern any act or fact that may constitute a violation of antitrust legislation (Law No. 287 of 10 October 1990 – Rules for the protection of competition and the market).
The Group safeguards the whistleblower ‘against retaliatory, discriminatory, or otherwise unfair actions resulting from the report,’ in an environment that respects the dignity of the whistleblower.
