In compliance with the applicable regulations, and in particular with Legislative Decree No. 24/2023, Syncro Group S.r.l. has adopted an internal procedure that allows individuals to submit reports, including anonymously, regarding criminal, civil, administrative, or accounting violations that may harm the public interest or the integrity of the company, and of which the reporting person has become aware within a work-related context.

Reports must concern violations discovered in the course of professional or work-related activities and must not be related to personal interests concerning exclusively the individual’s relationship with the company.

Who can submit a report

Reports may be submitted by:

  • Employees (including during the probationary period);
  • Self-employed workers and collaborators;
  • Employees or collaborators of the company’s suppliers;
  • Freelance professionals and consultants providing services to the company;
  • Volunteers and trainees, whether paid or unpaid;
  • Shareholders and persons performing administrative, management, control, supervisory or representative functions within the company;
  • Job applicants and potential suppliers.

Protection of the whistleblower

Syncro Group S.r.l. guarantees full protection of the whistleblower by ensuring:

  • Confidentiality of the whistleblower’s identity, of the facts reported, and of the identity of the persons involved. The dedicated reporting platform represents the preferred tool for submitting and managing reports, as it ensures the protection of such information through specific IT security measures.
    The identity of the reporting person will remain confidential and their data will be accessible only to the person responsible for managing the reports, unless the reporting person provides explicit consent or disclosure is required within the context of judicial proceedings.
  • Protection against retaliation or discrimination, whether direct or indirect, carried out against the whistleblower for reasons related to the report, which may affect the conditions of the relationship between the whistleblower and the company.

Within the reporting management process, personal data are processed in compliance with applicable data protection legislation (EU Regulation 2016/679 – GDPR and Legislative Decree 196/2003, as amended by Legislative Decree 101/2018).
Documentation and data related to the report will be retained only for the time strictly necessary to process the report and, in any case, for no longer than 5 years from the communication of the final outcome of the procedure.

Good faith requirement

Reports must be submitted responsibly and in good faith, and only when there are reasonable grounds to believe that the information regarding the reported violations is accurate.

If it is determined that a report has been deliberately made with false information, the reporting person may be subject to legal action for slander or defamation and may also face disciplinary sanctions, including financial penalties where applicable.

How to submit a report

Reports may be submitted through the following channels:

  • Orally, through the dedicated company telephone line: +39 0332 1260002

Content of the report

The content of the report is not subject to a specific format; however, it is important to provide as many details as possible (such as description of the facts, persons involved, dates, and any supporting documentation) in order to facilitate internal investigations.

Acknowledgment and feedback

Within 7 working days, the reporting person will receive confirmation that the report has been received and taken into consideration.

Within 3 months from the receipt of the report, during which the person responsible for managing the reporting channel may request additional information if necessary, the reporting person will receive feedback regarding the handling of the report.

If this does not occur, or if the reporting person has reasonable grounds to believe that the report has not been properly addressed through the internal channel or that using the internal channel may expose them to the risk of retaliation, it is possible to use the external reporting channel managed by ANAC: Whistleblowing – www.anticorruzione.it