Governance

Legislative Decree no. 24 of 10 March 2023, on “Implementation of Directive {EU} {UE} 2019/ 1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law and on provisions concerning the protection of persons who report breaches of national laws” (hereinafter referred to as the “Whistleblowing Decree”), significantly extended the scope of application of the rules on whistleblowing, previously limited, for the private sector, only to entities equipped with an Organisation, Management and Control Model pursuant to Legislative Decree no. 231 of 8 June 2001 (hereinafter the “Legislative Decree 231/2001”).

In particular, the Whistleblowing Decree has identified and regulated the reporting entities, the subject of reports of violations, the channels to be set up, and the obligations and protections that companies are required to implement and guarantee, also defining the criteria and timeframes for compliance.

As the management of the reports involves the collection and processing of personal data, the relevant legislation on the protection of personal data and in particular Regulation (EU) 2016/ 679 of the European Parliament and of the Council, dated 27 April 2016, “on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC” (General Data Protection Regulation, Genera/ Data Protection Regulation, hereinafter, the “GDPR”) and Legislative Decree 30 June 2003, no 196 “Personal Data Protection Code”, as amended by Legislative Decree No. 101 of 10 August 2018 (hereinafter, the “Privacy Code”).

DIES S.r.l. (hereinafter, “DIES” or the “Company”) had already equipped itself, in the context of its Organisation, Management and Control Model pursuant to Legislative Decree 231/2001 (hereinafter “Model 231”) with a system for making and managing reports of violations and, in the light of the regulatory changes outlined above, has revised its logic and tools. In order to safeguard the values of legality, the correctness and integrity expressed in its code of ethics (hereinafter, the “Code of Ethics”), DIES supports and encourages anyone who intends to report a potential illegal, inappropriate, improper conduct or alleged violation of the principles expressed in the Code of Ethics, in the 231 Model, in its policies and, in general, potential violations of laws and regulations.

In fact, each report contributes to the success of the Company and to the promotion of an ethical, healthy and sustainable culture, offering an important contribution to the internal compliance control system.