|What is the purpose of Whistleblowing?
Whistleblowing serves to ensure and provide everyone with simple ways to report any violations of the law or the Company's Code of Ethics – in addition to other provisions outlined in the procedure adopted by CSO – in order to allow the Company to take on and verify the existence of any reported violations.
|Who can report a violation?
Anyone can make a report, including employees, former employees, shareholders, customers, partners, suppliers, freelancers, or individuals with collaboration agreements, professionals, consultants, and agents. In other words, anyone who is currently or has ceased collaboration with CSO, related to events or matters concerning CSO's business activities, holds the power to report.
|What can be reported?
It is important to note that reports related to complaints, disputes, or other aspects linked to personal interests (e.g., changes in one's job position) are not considered and will not be taken into account. Instead, reports can be made regarding violations attributable to CSO, such as violations of laws and regulations, CSO's Code of Ethics, offenses outlined in the Organizational Model 231 (e.g., corruption), and the current rules and procedures within CSO.
|How can one make a report?
CSO, in compliance with regulations and recent ANAC Guidelines, provides the option to make reports through a specific digital platform, the access details of which are provided to all concerned parties through a specific notice. This platform allows individuals to submit reports in writing or through a voicemail, ensuring maximum confidentiality.
All reports are forwarded to CSO's OdV (Organismo di Vigilanza) which, within 7 days of receiving each request, must confirm the receipt and, within three months, communicate its assessments and final decisions on the received report. Therefore, it is crucial that the report is adequately detailed, providing enough information to outline specific and consistent circumstances and facts related to certain contexts and allowing the identification of elements useful for verifying the validity of the report (e.g., identification of involved parties, context, location, and timeframe of reported events, and supporting documentation).
|How to access the Reporting Portal?
The digital portal is accessible from the dedicated "Whistleblowing" page on CSO's website.
Upon completion, the reporter must note the date and the Unique Identifying Code (an alphanumeric ticket uniquely identifying the report) automatically generated by the portal. This code allows tracking the status of the report over time and facilitates sending and receiving communications (even anonymously). Supporting documentation can be attached to the report, even after submission.
|Is it possible to make an anonymous report?
Yes, CSO's system allows for anonymous reporting.
The platform enables confidential dialogue with the reporter (even anonymous) by accessing the report's date and the Unique Identifying Code generated during submission.
|Am I protected if I feel the need to make a report?
The identity of the reporter and any information that could identify them cannot be disclosed without the reporter's consent.
It is important to note that any act of retaliation against the reporter is considered void. If someone believes they have faced retaliation due to a report, they can report it to the National Anti-Corruption Authority (ANAC). Protection measures, including the prohibition of retaliation, also extend to facilitators, colleagues, and relatives of the reporter, as well as legal entities connected to the reporter.
|Is there an authority ensuring the correctness of the reporting system?
If the reporting system is not active or not compliant with the law, or if there is no acknowledgment of receipt or response within the maximum period of three months, or in other cases specified by the law, a report can be made to ANAC. ANAC provides its own digital platform to receive reports in such cases.
|Guide to a reporting page