CHATTERBOX S.R.L. (C.F. 02587260924), with registered office in Cagliari (CA) Via Tempio n. 15, CAP 09127, in person of its pro tempore legal representative, has adopted a whistleblowing management system that complies with the regulatory requirements on Whistleblowing Legislative Decree no. 24/2023 (which transposes Directive (EU) 2019/1937 of the European Parliament and of the Council into Italian law, of 23 October 2019 on the protection of persons who report breaches of Union law and on the protection of persons who report breaches of national legal provisions) promoting transparency and high ethical standards.
Personnel and third parties may make reports in written, oral or face-to-face form concerning information on the violations of which they, the so-called whistleblowers, have become aware of in the work context and that they believe may constitute a violation of the rules governing the activity carried out by the Company.
Behaviours, acts or omissions that are detrimental to the public interest or integrity may be reported: this is, therefore, information, including well-founded suspicions, concerning violations committed or which, on the basis of concrete evidence, could be committed in the organisation in which the reporting person has a legal relationship, as well as conduct aimed at concealing such violations.
CHATTERBOX S.R.L., by applying the discipline provided for by Legislative Decree no. 24/2023, ensures the protection of the whistleblower in good faith against any act, action, retaliatory behaviour directly or indirectly related to the report.
The whistleblower must act in good faith, making detailed reports based on precise and consistent facts. They must refrain from making reports that are clearly unfounded or not substantiated: therefore, in the event of unfounded and/or bad faith reports, CHATTERBOX S.R.L. reserves the right to act in defence of its interests and to protect the injured parties.
The provisions of Legislative Decree no. 24/2023 do not apply, on the other hand, "to disputes, claims or requests related to a personal interest of the reporting person that relate exclusively to their individual employment or public employment relationships, or inherent to their employment or public employment relationships with hierarchically superior figures". In addition, the report may not relate to information that is already in the public domain.
In order to pursue the objectives imposed by Legislative Decree 24/2023, CHATTERBOX S.R.L. has activated an internal reporting channel that protects the confidentiality of the identity of the reporting person, the person involved and the person in any case mentioned in the report, the content of the report and the related documentation.
This internal channel (including all the reporting methods listed below) is managed by the Calvello Law Firm in person of Avv. Claudio Calvello, member of the Padua Bar Association, external to the company, autonomous and specifically trained.
Internal reports can be made through the following channels set up by the Company:
The IT platform is the preferred tool for sending and managing reports, as it is most suitable for ensuring, by electronic means, the confidentiality of the Whistleblower's identity and adequate information security measures.
In any case, the Whistleblowing Manager, in the person of Avv. Claudio Calvello, guarantees that the information acquired will be treated with the utmost care and absolute confidentiality.
When he receives a report, Avv. Claudio Calvello sends the whistleblower, within seven days, an acknowledgment of receipt and acceptance. He then follows up on the report, maintaining discussions with the whistleblower and requesting any clarifications and additions to the documents or information that may be necessary. Once the existence of the conditions provided for by the provisions of Legislative Decree 24/23 has been verified, he carries out the investigations he deems appropriate and provides feedback to the whistleblower within three months from the date of the acknowledgement of receipt or, in the absence of such notice, within three months from the expiry of the seven-day period from the submission of the report.
Please read carefully the instructions contained in the Whistleblowing Procedure (available at the bottom of this page) before submitting your internal report. Only under certain conditions provided for by the legislation, it is possible to make external reports directly to the National Anti-Corruption Authority (ANAC). Information on the channel, procedures and requirements for making external reports can be found in the Procedure.
Please read the privacy policy at the bottom of this page.
