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Whistleblowing
A confidential channel to report unlawful conduct, in line with the protections set out by Italian Legislative Decree 24/2023.
A confidential channel to report unlawful conduct, in line with the protections set out by Italian Legislative Decree 24/2023.
Valuemate S.r.l. promotes a corporate culture based on integrity, transparency and accountability. Consistent with these principles and in implementation of Italian Legislative Decree 24/2023, which transposes Directive (EU) 2019/1937, the company provides a dedicated channel for reporting unlawful conduct that comes to light in the work context.
"Whistleblowing" refers to the reporting, by those who operate within an organisation, of breaches of legal provisions or unlawful conduct of which they have become aware in the course of their activity. The aim is to bring to light, in a timely manner, situations of risk or harm to the public interest or to the integrity of the company, so that action can be taken.
The channel is open to a wide range of people who operate in relation with the company: employees, collaborators, consultants, self-employed professionals, trainees and volunteers, suppliers, as well as candidates during recruitment and individuals whose relationship has ended. Protection also applies to those who report during the pre-contractual phase or after the relationship has concluded.
Reports may concern breaches of national and European legal provisions that harm the public interest or the integrity of the organisation: for example administrative, accounting, civil or criminal offences, conduct breaching EU rules on public procurement, financial services, product safety, environmental protection, personal data protection and network security. Personal grievances or claims solely connected to the individual employment relationship fall outside the scope of the channel.
Italian Legislative Decree 24/2023 guarantees those who report in good faith a number of fundamental protections:
Confidentiality. The identity of the whistleblower and any information from which it may be inferred, directly or indirectly, are protected and may not be disclosed without the person's consent, except where required by law.
Prohibition of retaliation. Any form of retaliation against the whistleblower (such as dismissal, demotion, transfer, sanctions or other detrimental measures) adopted because of the report is prohibited.
Protection of related persons. Protection also extends to facilitators, colleagues and relatives of the whistleblower, as well as to entities connected to them.
To ensure confidentiality and security, reports are submitted through the dedicated portal, accessible via the link below. The portal allows reports to be sent confidentially and their status to be followed over time.
Legal reference: Italian Legislative Decree no. 24 of 10 March 2023, implementing Directive (EU) 2019/1937.
This notice describes the processing of personal data carried out in the context of managing whistleblowing reports, pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR).
The Data Controller is Valuemate S.r.l., with registered office in Turin, Corso Re Umberto no. 65, Italy. Email: info@valuemate.it · certified email (PEC): valuemate@legalmail.it.
Personal data is processed to manage reports of unlawful conduct (whistleblowing), to comply with legal obligations (Italian Legislative Decree no. 24/2023) and to establish, exercise or defend a legal claim.
Processing is based on the legal obligation to which the Controller is subject (Art. 6(1)(c) GDPR), on substantial public interest (Art. 6(1)(e) GDPR) and, where necessary, on the processing of special categories of data pursuant to Art. 9 GDPR.
The following may be processed: identifying data of the whistleblower (if provided), data of the reported person, data of any third parties involved and the information contained in the report.
Personal data may be collected directly from the whistleblower or from third parties in the course of the investigation.
Processing is carried out using electronic and/or paper-based tools, in compliance with the principles of lawfulness, fairness, transparency and minimisation. Appropriate technical and organisational measures are adopted to ensure the security and confidentiality of the data.
Data may be disclosed to authorised internal persons, to the Supervisory Body (where present), to judicial or administrative authorities and to consultants and suppliers appointed as data processors.
Data is not transferred outside the European Economic Area. Otherwise, any transfer will take place in compliance with the safeguards provided by the GDPR.
Data is retained for the time necessary to manage the report and in any case no longer than 5 years from the communication of the final outcome.
Data subjects may exercise the rights set out in Articles 15-22 GDPR, including access, rectification, erasure, restriction of processing and objection. These rights may be limited in the cases provided for by whistleblowing legislation.
Pursuant to Art. 2-undecies of the Italian Privacy Code, the exercise of rights may be limited in order to protect the confidentiality of the whistleblower's identity and the proper conduct of investigations.
The provision of data is optional but necessary for the effective management of the report.
This notice may be updated at any time. The updated version will be made available through company channels.
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