Whistleblowing

Welcome to our Reporting Channel
You may use our internal reporting channel—also referred to as the whistle-blowing function—to report suspected misconduct or wrongdoing within our organisation.

Who Can Make a Report?

Reports may be submitted by anyone working in a professional capacity for or with Pooleng, including:

employees
self-employed workers and external collaborators
freelancers, suppliers and consultants
volunteers and interns (paid or unpaid)
candidates and persons on probation or in the interview stage
shareholders and individuals performing administration, management, control, supervision or representation functions—even if exercised de facto

When Can a Report Be Made?

A report may be filed:

while the working relationship is active
before it begins, if information was obtained during recruitment or other pre-contractual phases
during any probation or interview period
after the relationship has ended, provided the information was acquired beforehand (e.g. by retirees)

What Can Be Reported?

You may report any behaviour, act or omission that harms the interests or integrity of Pooleng and that amounts to:

breaches of national law (administrative, accounting, civil or criminal)
unlawful conduct relevant under Legislative Decree 8 June 2001, No. 231 (e.g. unlawful receipt of funds, fraud against the State or the EU, computer fraud against public bodies, fraud in public procurement)
violations of the organisation and management models adopted under that Decree

You may also report breaches of European Union law in areas such as public procurement, financial services and markets, anti-money-laundering, product and transport safety, environmental protection, radiation and nuclear safety, food and feed safety, animal health and welfare, public health, consumer protection, privacy and data protection, and network and information-systems security. This includes acts or omissions that:

damage the EU’s financial interests
distort the internal market (e.g. competition or State-aid infringements)
frustrate the object or purpose of EU provisions

Information may concern violations already committed or not yet committed that, on reasonable grounds, you believe are likely to occur, as well as any attempts to conceal such breaches.

What Cannot Be Reported, Disclosed Publicly or Denounced?

complaints, claims or requests that relate solely to your own personal employment matters
matters already covered by mandatory EU or national legislation listed in Part II of the Annex to Legislative Decree 24/2023 or implementing Directive (EU) 2019/1937
issues involving national security, or defence or security contracts, unless they fall within the scope of relevant EU law

Handling Your Report

Upon receipt, the appointed Reporting Manager will:

acknowledge the report within seven (7) days;
maintain communication with you and, where necessary, request further information;
follow up diligently and provide feedback within three (3) months of acknowledgement—or, if no acknowledgement was sent, within three (3) months of the eighth day after submission.

Protection System

The safeguards afforded to whistle-blowers and other parties are set out in Articles 12 ff. of Legislative Decree 24/2023. Key points include:

Data Protection – Personal data are processed in strict confidence, using measures such as encryption, in full compliance with applicable data-protection legislation.

Confidentiality – Reports are exempt from public-records access. Your identity (and that of anyone mentioned) must not be revealed to anyone other than those authorised to handle the report. This prohibition extends to any elements from which your identity could be inferred.