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This information page explains the operation of the internal channel for reporting wrongdoing or irregularities within Valetudo, implementing the provisions of the new Italian Legislative Decree 24/2023 on whistleblowing, which requires our compliance. The whistleblowing channel is accessible online, at this link, and is managed internally within Valetudo. As indicated in the last section of this document, individuals may also use external whistleblowing channels.

The term “whistleblowing” refers to a set of rules designed to protect individuals from retaliation, in the case they report wrongdoing or irregularities within Valetudo.

The purpose of the internal whistleblowing channel is to ensure the confidentiality of the whistleblower and protect them from any retaliation being caused by their report. Such protections would not be guaranteed in the case of an ordinary report, to a contact person or superior.

The internal whistleblowing channel is for use: by employees and former employees of Valetudo; by partners and persons with administrative, management, control, supervisory or representative functions; by external parties (consultants, employees of suppliers of goods and services, trainees, volunteers) who carry out operations either for Valetudo or within its facilities; by candidates for a position with the company.

The reporter can choose whether or not to submit the report anonymously. In case of opting for anonymity, the individual will still have the right to be kept informed on the progress of resulting investigation, and may be contacted through the platform at a later time for further information instrumental to its handling. In any case, the confidentiality of the reporter and the other persons involved will be fully guaranteed.

Legislative Decree 24/2023 clearly specifies the violations encountered in the work environment which can be subject to reporting, i.e.: violations of European law (e.g. dissemination of personal data of Valetudo employees) or of national law in civil matters (e.g. damage to company property), criminal matters (e.g. behaviour qualifying as mobbing; accepting a sum of money to influence the choice of a supplier), administrative matters (e.g. use of cash exceeding the legally indicated thresholds), accounting matters (e.g. incorrect declaration of taxes).

Individuals may not use the Valetudo channel for reporting matters exclusively pertaining to their individual employment relationships, nor for matters otherwise pertaining to Human Resources (HR), or subjects of Health, Safety and the Environment. For these matters, individuals should contact the respective departments. Moreover, reports cannot be submitted on national security violations, nor on procurement related to defence or national security, unless these aspects are covered by relevant EU secondary legislation.

The whistleblowing channel is not to be used for reports pertaining to violations of the internal procedures or the management systems adopted by Valetudo in accordance with ISO procedures (e.g. failure to comply with a GMP/ISO standard), except in the case that such violations are in turn reportable under Italian Legislative Decree 24/2023.

Having clarified the subjects of reporting, those reporting should also be aware of the necessary content. Reports must contain precise and complete information on the facts, the circumstances of time and place, the persons involved, and on the essential elements of the problem subjects. Reports may also be based on well-founded suspicions regarding the commission of violations, or concrete, precise and substantial information on events not yet occurred. In addition, individuals may also report conduct aimed at concealing violations.

If the reporter (incorrectly) sends a report on a channel other than the above web portal, and wants to keep their identity secret and benefit from the protections provided in case of retaliation, they should indicate this in the subject line of the report.

A reporter who has reported in good faith on a perceived violation will not be subject to any disciplinary action related to the report, nor to retaliation of any kind, even if the report is later found to be inaccurate or unfounded.

On the other hand, anyone who knowingly and deliberately submits a false report or false statements, disseminates misleading information or acts in bad faith (e.g. by submitting defamatory or slanderous complaints), will lose all rights to the protections provided for the reporter under Italian Legislative Decree 24/2023, and will be subject to the relevant sanctioning consequences (including criminal), in accordance with the Valetudo Disciplinary Code, company procedures and applicable laws. The same consequences will occur in case of malicious use of external reporting channels.

As required by Legislative decree 24/2023, Valetudo is committed to taking all necessary measures to ensure the protection of the whistleblower, the reported person and any others involved in the report, including the procedural facilitator, so as to safeguard them from damage to their reputation and from any other negative consequences. These protections take effect even before the content of any reporting is known.

Valetudo and any external parties involved in reporting ensure the utmost protection of all personal data processed, preventing the undue circulation of personal information to parties not authorised to process such data, whether outside or inside Valetudo offices.

In addition, in the event of proceedings resulting from a report, the persons reported and otherwise involved maintain all the guarantees of defence as normally recognised in any disciplinary or other proceedings.

Any retaliation must be reported immediately to the Italian National Anti-Corruption Authority (ANAC) through the relevant external reporting channel. Once the responsibility of the perpetrators of retaliatory conduct is established, they will be subject to disciplinary measures by Valetudo. Valetudo may also take action in cases of conduct obstructing the right to report, in accordance with the applicable laws.

The report is received by a three-person committee (hereafter, the “Whistleblowing Committee”), namely, two Valetudo employees (the current HR Manager and IT Manager) and a qualified external professional (the Labour Consultant appointed by Valetudo for whistleblowing matters). The Committee will deal with the report in cooperation with a qualified investigator, identified as the best person to handle that particular report.

If a person receives a report without being competent to do so, they shall: (i) promptly forward the report to the Whistleblowing Committee; (ii) maintain strict confidentiality regarding the content of the report and the individuals involved, if they have become aware of these matters. These indications also apply in the case of a report received by a competent person through an incorrect channel (e.g., reporting by e-mail instead of through the portal).

To submit a report, the whistleblower must first register on the Valetudo Whistleblowing Portal. When the reporter registers an account on the platform, the system assigns them a non-revealing nickname and requires them to enter a password of their choice. The reporter must remember their nickname and password, to be able to enter reports and follow up on progress. Upon entering a report on the platform, the reporter will immediately receive confirmation of receipt, and within seven days will receive a second notice that the report has been taken into consideration, following which the report handler will remain in direct contact for the duration of the investigation. In any case, within three months after submission of the report, the individual will receive the final report with the outcome of the investigation.

If the reporter provides their e-mail contact while registering on the portal, they will receive e-mail notifications about all events that require further access, such as to check progress on the report handling, to respond to messages, etc.

The e-mail contact can also be used to recover a lost or forgotten password.

A lost nickname cannot be recovered in any way.

If, on the other hand, the reporter has not provided their own email contact, they remain responsible for logging into the portal periodically, to follow the progress of the report management and respond to any messages. In the absence of an email contact, the reporter will be unable to recover a lost or forgotten password; i.e. if they lose their nickname or password, they lose all access to their account.

Throughout the entire proceeding of collecting and managing a report, Valetudo carries out the processing of the personal data of all those involved in full compliance with the provisions of the privacy legislation, in the manner and within the limits illustrated in the privacy policy available at the following link. The exercise of the rights normally guaranteed to the person concerned could be limited, however, as this could result in actual and concrete prejudice to protection of the confidentiality of the reporting person’s identity.

Under certain conditions, an individual may also submit their report through external channels, namely:

a) on the ANAC website, under the following conditions:

– an internal report was submitted but there was no follow up;
– there is good reason to believe that the internal reporting will not be followed up;
– the reportable matter constitutes an imminent danger requiring reporting to an authority;

b) by public disclosure, under the following conditions:

– both internal and external reports have been submitted and there has been no follow up;
– the reportable matter constitutes an imminent danger requiring reporting to the community;
– there is a real risk of retaliation if reporting is done through a different channel.

The submission of a report through the use of an external channel, in the absence of the conditions provided for in Italian Legislative Decree 24/2023, brings about the loss of the protections recognised to the reporter under Article 20 of the Decree, and brings into effect the related responsibilities (including criminal) attributable the reporter.

The whistleblower maintains access to all legally recognised channels for reporting to authorities on criminal or administrative offenses (e.g., filing a report on a crime with police), provided the relevant prerequisites are met.

For any information pertaining to whistleblowing please contact the Steering Committee at: whistleblowing@valetudo.com

Please note that this e-mail address should NOT be used to enter reports. Reports should be made by accessing the portal via the link at the top of this page.