Whistleblowing

Whistleblowing: report non-compliant behaviour safely and confidentially

What is whistleblowing and why does it matter

Whistleblowing is the mechanism through which employees, collaborators, suppliers and other parties involved in company life can report — safely and confidentially — potentially unlawful, irregular or values-violating conduct they become aware of in the workplace.

In Italy, Legislative Decree no. 24/2023 — which implements EU Directive 2019/1937 — has reshaped the protection framework for whistleblowers, introducing precise obligations for companies and guaranteeing concrete safeguards for those who report in good faith. Sacemi Gamar has implemented its whistleblowing procedure in full compliance with this legislation and with the Guidelines issued by ANAC (the Italian National Anti-Corruption Authority).

Who can submit a report

Sacemi Gamar's whistleblowing channel is open to all parties who operate — or have operated — within the company's sphere, regardless of the nature of their relationship:

• Employees and subordinate workers (fixed-term and permanent)
• Collaborators, consultants and self-employed professionals
• Suppliers and commercial partners
• Trainees and volunteers
• Shareholders, directors and members of supervisory bodies

The protections provided by law also apply to those whose working relationship has ended — provided the reported facts were acquired during that relationship — and to those who have not yet begun one (pre-contractual phase).

What can be reported

Sacemi Gamar's whistleblowing channel is intended for reporting conduct in breach of:

• The company's Code of Ethics
• The Organisation, Management and Control Model under Legislative Decree no. 231/2001
• The Environmental Policy and applicable environmental regulations
• Internal company policies and procedures
• National and European Union regulatory provisions (administrative, civil, accounting or criminal violations)

Reports may also cover conduct that, while not constituting a criminal offence, could cause harm — including reputational harm — to Sacemi Gamar or its stakeholders.

How the reporting channel works

To ensure maximum effectiveness, confidentiality and regulatory compliance, Sacemi Gamar has adopted a dedicated digital platform managed by an independent, specialist third party. This approach guarantees:

• Anonymity for the reporter: the identity of the person submitting the report is protected at every stage of the process, in accordance with Article 12 of Legislative Decree no. 24/2023.
• Absolute confidentiality: all information relating to the report, the parties involved and the facts described is handled with the utmost discretion.
• Protection from retaliation: anyone who reports in good faith is protected from any form of retaliation, discrimination or demotion, as required by applicable law.
• Professional handling: the platform ensures that all reports are managed correctly and within the timeframes prescribed by law.

Access the reporting portal

Sacemi Gamar encourages all stakeholders to use the whistleblowing channel whenever they feel it necessary to flag a potentially irregular situation. Reporting in good faith is an act of responsibility towards the company, colleagues and the wider community.

→ Access the Whistleblowing Portal

Protections for the reporter

Legislative Decree no. 24/2023 guarantees extended protections not only to the direct reporter, but also to so-called "facilitators": colleagues, relatives and other individuals who support the whistleblower in the reporting process. Where retaliation is confirmed, the law provides for sanctions of up to €50,000 against the responsible party.

Sacemi Gamar is committed to handling every report with seriousness, impartiality and full respect for the rights of all parties involved.