The ENREACH GROUP has a whistleblowing channel so that those aware of serious infringements or offences committed during the course of their activity or relationship with the company can use a tool to report irregularities confidentially. The channel is the communication instrument that forms part of the organisation’s internal information system.

Who can report/complain through the whistleblowing channel

Company employees, former employees, volunteers, trainees, trainees in training, applicants, self-employed persons, partners, staff of contractors, subcontractors and suppliers, legal representatives of employees or natural persons advising the informant, natural persons who are related to the informant and who may suffer retaliation, such as co-workers or relatives of the informant, legal persons, for whom he/she works or with whom he/she has any other relationship in an employment context or in which he/she has a significant shareholding.

What can be reported

•  Actions or omissions that may constitute breaches of European Union law.

•  Actions or omissions that may constitute a serious or very serious criminal or administrative offence.

•  Infringements of labour law in matters of health and safety at work.

This channel is not an instrument for communicating labour or commercial complaints within the ENREACH GROUP.

The channel must be used in good faith. If the person making the complaint is aware of the untruthfulness of the information provided, or with the sole purpose of denigrating the person or institution being reported, he/she may be held liable.

Confidentiality and non-retaliation

This system guarantees the confidentiality of the whistleblower and any third party appearing in the communication both legally and technically and allows for anonymity.

The system is also subject to the principle of non-retaliation for any of the whistleblowers or third parties. When the organisation becomes aware that the whistleblower or informant has been subjected to acts of intimidation or retaliation, it will promote or exercise the appropriate corrective or restorative actions.

Anonymous reporting

The complaint can be anonymous; the most important thing is the credibility of the facts, not the person making the complaint. Anonymity, however, makes it difficult to maintain an open channel of communication with the complainant, which facilitates the process of analysis and investigation. Furthermore, depending on the type of offence reported (especially if it directly affects the complainant), anonymity can also make the investigation significantly more difficult.

Processing of the complaint

Sending the complaint automatically generates a reception number available to the complainant. The report is passed on to the ENREACH GROUP’s compliance manager and the analysis and investigation phase begins.

The proceedings will be carried out with the utmost confidentiality and secrecy, in accordance with the law.

Within a maximum period of three months (extendable by a further three months in the event that the investigation is particularly complex), the company will inform the complainant of the content of the resolution resulting from the complaint.

Communication with the complainant may be maintained or additional information may be requested.

If its investigations reveal indications of a criminal offence, the facts will be transferred to the Public Prosecutor’s Office or the judicial authority.