Corporate Governance

FAQ

    Reports are received and analysed by the Whistleblowing Committee composed by the Head of Internal Audit & Risk Management, the Head of Human Resources & Organization and the Head of Legal Affairs & Compliance.
    If a Report refers to a member of the aforementioned Committee, the reported person shall not be involved in any activity regarding the process of receiving, analysing and processing the Report.
    Aggregated data regarding Reports received as well as any detailed information arisen from the analysis of significant Reports may be shared – depending on the topic and specific areas of responsibility – with the Surveillance Body ex L.D. 231/01, the Board of Statutory Auditors and -  if deemed appropriate - with the Top Management.
    Italo shall guarantee confidentiality and protection of Whistleblowers identity with the aim of eliminating any element that may discourage anyone from submitting reports. The Company will take into consideration anonymous Reports only if they are timely, substantiated and backed by adequate documentation and it is required that Whistleblowers indicate their personal data to allow the company to ask for further evidence and information while analysing and managing the Report.
    Italo’s Whistleblowing IT platform stores data on a dedicated server and guarantees confidentiality of the Whistleblower’s identity as:
    • IPs and servers from which Reports were submitted are not traced (“no log policy”);
    • Reports and ID data are stored in separated databases;
    • An anonymous ID code is automatically assigned to every single Report.
    Therefore, from the moment in which the report is received and during its processing, only the anonymous ID code will be visible into the platform.
    Italo’s Whistleblowing Committee and its members (the Head of Internal Audit & Risk Management, the Head of Human Resources & Organization and the Head of Legal Affairs & Compliance).
    In the cases foreseen by the law, the identity of the Whistleblower can be viewed only inside the IT platform through a function that stores activity logs regarding the person who and the reasons why identity has been disclosed.
    ITALO shall treat all data acquired through the Report in compliance with Regulation n. 2016/679 (“GDPR”) and with any applicable internal procedure. Therefore:
    • the Company shall not disclose to the reported person the identity of the Whistleblower, but for the cases foreseen by the law in order to avoid retaliation, threats, violence, etc. and to protect the Whistleblower’s confidentiality;
    • as part of disciplinary proceedings against the reported person, the identity of the whistleblower may be disclosed only with the whistleblower's express consent, if the dispute is based - in whole or in part - on the report and knowledge of the whistleblower's identity is essential for the defense of the accused person. In that case, the Company will ask the whistleblower's consent to the disclosure of his / her identity by notifying in writing the reasons for the disclosure of his / her confidential data.
    You can submit a report by:
    • accessing the Whistleblowing platform using a private and/or non-company owned fixed/mobile device.
    • filling the form with all the required information
    • don’t forgetting to thick the appropriate field to let us aware that you are an ITALO “employee”.
    You can either send a letter to the Company: Italo Via Casilina 1 - 00182 Rome, to the attention of the Whistleblowing Committee in the person of the Head of Internal Audit and Risk Management Function.
    Moreover, you can submit oral Reports through a direct meeting with the Whistleblowing Committee or one of its members.
    External parties can submit a report by accessing the Whistleblowing platform using any fixed or mobile device with an Internet browser and by inserting the following data: name, surname, email address and phone number.
    They can also send a letter to the Company: Italo Via Casilina 1 - 00182 Roma, attention of the Whistleblowing Committee represented in the person of the Head of Internal Audit and Risk Management Function.
    Moreover, they can submit oral Reports through a direct meeting with the Whistleblowing Committee or one of its members.
    Please note that Italo will acknowledge anonymous Reports only if they are timely, substantiated and backed by adequate documentation.       
    Whistleblowers can monitor the progress of their Reports by accessing the Whistleblowing portal and by inserting the ID code (10 digits / numeric code) provided by the portal at the time the Report was submitted.
    The IT platform allows you to attach text, image, audio and video files to your Report for up to 60 mb.
    Whistleblowers can monitor the progress of their Reports by accessing the Whistleblowing portal and by inserting the ID code (10 digits / numeric code) provided by the portal at the time the Report was submitted.Specific channels are provided for internal reporting (see FAQ 6 and FAQ 7), external reporting and public disclosures.
    In fact, applicable regulation provides for the possibility of forwarding external reporting the Italian Anticorruption Authority (ANAC) in the following hypotheses:
    (i) the internal reporting channel is not active or does not comply with legal requirements;
    (ii) the internal report previously submitted by the whistleblower has not been followed-up;
    (iii) the whistleblower has reasonable grounds to believe that:
    • the internal report has not been effectively investigated;
    • a risk of retaliation may occur;
    • the alleged breach may cause an imminent or manifest danger to the public interest.
    Guidelines and procedures for submitting and handling external reports are published on the ANAC website.
     
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