In compliance with the law and to ensure fairness and transparency in the conduct of their business, the insurance intermediaries of the Group have adopted an IT whistleblowing system, available to anyone who wishes to report situations that are relevant under the law or internal regulations.
Requirements for a report
A report must relate solely to breaches of the law or of internal procedures and regulations, including the Code of Ethics. Reports concerning complaints, personal requests or, more generally, irrelevant circumstances may be disregarded.
Reports must be made in good faith, be detailed and be based on precise and consistent facts, so as not to undermine the effectiveness of the tool made available. Anyone who, with intent or gross negligence, makes reports that subsequently prove to be unfounded may be subject to disciplinary sanctions.
How reports are handled
To provide the greatest possible protection to both the person making the report and the person reported, the necessary security measures have been adopted: whether the report is made anonymously or not, the confidentiality of the reporter’s identity and of the content of the report is guaranteed through secure protocols and encryption tools that protect the personal data and information provided. The reporter’s identity is never disclosed without their consent, except in the cases provided for by the applicable law. Reports are handled by the Reporting Office (Ufficio Segnalazioni).
How to submit a report
- Open the link of the relevant company listed below and fill in the form with your first name, last name and a personal email address (please do not use your work address, as required by the Italian Data Protection Authority).
- Follow the instructions in the email containing your unique access credentials.
- Log in to your account with your credentials.
- Click the “CREA SEGNALAZIONE” (Create report) button.
- Proceed with the report (a) anonymously, using the dedicated option, or (b) not anonymously, but in any case with the confidentiality safeguards provided for by law. The report may be submitted in writing or orally by recording a voice message, where the reporting system allows it. In both cases, tools are provided to guarantee the reporter’s anonymity.
- Once you have chosen how to report, fill in the form. Fields marked with * are mandatory; some open fields require a minimum number of characters.
The Reporting Office is available for any further questions or clarification.
Reporting links of the Group companies
External reporting channel at ANAC
Without prejudice to the procedure described above and in accordance with the applicable law, the reporter may, as a last resort, use the external reporting channel of ANAC (the Italian National Anti-Corruption Authority) where one of the following conditions is met:
- the reporter has already made an internal report and it has not been followed up;
- the reporter has reasonable grounds to believe that, if they made an internal report, it would not be effectively followed up, or that there is a well-founded risk of retaliation;
- the reporter has reasonable grounds to believe that the breach may constitute an imminent or manifest danger to the public interest.
For further information on how internal reports are submitted and handled, please refer to the Whistleblowing Procedure available on the company SharePoint.