Medical director: Doc. Cinchini Elisabetta

Quisisana
Whistleblowing Reports

PROCEDURE FOR INTERNAL REPORTING UNDER LEGISLATIVE DECREE 24/2023
(WHISTLEBLOWING)

Pursuant to Art. 6, paragraph 2-bis of Legislative Decree 231/2001 and Legislative Decree 24/2023 Quisisana has procedures in place to enable the reporting of unlawful acts concerning both the violation of the Organizational Model 231 and, therefore, detrimental to the interests of the private entity, and, more generally, acts detrimental to public interests or the integrity of the public administration committed within the organization of the Entity.

Reports of violations of the Model may be made exclusively through the internal reporting channel. All other reports may be made through internal reporting channel, external, public disclosure or report to the authority.

OBJECT OF REPORTING

The following may be reported:

1) administrative, accounting, civil or criminal offenses that do not fall under numbers 3), 4), 5) and 6);

2) illegal conduct relevant under Legislative Decree No. 231 of June 8, 2001, or violations of the organization and management models provided therein, which do not fall under numbers 3), 4), 5) and 6);

3) offenses that fall within the scope of application of the European Union or national acts indicated in the Annex to this Decree or national acts that constitute implementation of the European Union acts indicated in the Annex to Directive (EU) 2019/1937, although not indicated in the Annex to this Decree, relating to the following sectors: public procurement; financial services, products and markets and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; privacy and personal data protection and network and information system security;

4) acts or omissions affecting the financial interests of the Union referred to in Article 325 of the Treaty on the Functioning of the European Union specified in relevant secondary legislation of the European Union;

(5) acts or omissions affecting the internal market, as referred to in Art.

REPORTING SUBJECTS

The report must relate to violations learned in the reporting party's work environment. The reporter can, therefore, be either the employee or any other person who has a qualified relationship with the entity (e.g., consultants, volunteers, shareholders, trainees, people with administrative, management and control functions, etc.)

CHARACTERISTICS OF REPORTS

The report must be as circumstantial as possible and more specifically must be clear:

The circumstances of time and place in which the reported fact occurred

The description of the fact

The particulars or other elements that make it possible to identify the person responsible for the facts reported

Reports must be made in good faith, without prejudice to the responsibility of the person making the report if the report includes the cases of slander and/or defamation or other criminal acts.
Documents may be attached to the report in order to provide useful elements for the assessment of its merits.

INTERNAL REPORTING MODALITIES

Reporting through computer platform that can be reached by clicking on the box at the bottom of this page, following all the instructions therein.
The report may be made in non-anonymous form with all the guarantees of confidentiality provided by law or in anonymous form, provided that they are always substantiated.

Reporting in oral form through direct interview with the SB (body, as specified below deputed to the management of reports). In this case, the SB will proceed, with the consent of the reporter, to record the interview and verbalize the information gathered. In case of disagreement with the recording, only the verbalization will be carried out.

MANAGEMENT OF REPORTS

The management of the report is entrusted to the Supervisory Board, according to the special procedure provided in the 231 Organizational Model to which reference should be made for any necessary further details.
In order to protect the reporter and the reported and, more generally, all those involved, the necessary security measures have been taken to ensure confidentiality.
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