Whistleblowing

SANCO S.p.A. promotes an open corporate culture grounded in ethics, transparency, and accountability, inspired by the Company’s core values.

For this reason, it calls on all individuals involved with the Company, such as directors, executives, supervisory bodies, managers, employees, collaborators, and partners, to operate in full compliance with applicable laws and regulations, the Ethics Policy and the Human Rights.

The Company strongly encourages its stakeholders to report (commonly known as whistleblowing) any misconduct, dishonest or illegal activity, whether potential, highly likely, or already committed—as well as any behaviour that could cause harm or damage, including reputational harm, to SANCO S.p.A.

To this end, the Company has implemented specific rules and a dedicated management process in compliance with the “Whistleblowing” regulation (Legislative Decree 24/2023), offering secure channels that ensure the confidentiality of the whistleblower’s identity and the information reported, along with protection against any form of retaliation.

Reports concerning the personal interests of the whistleblower, individual complaints or grievances of a personal or commercial nature, or matters regulated by employment law fall outside the scope of this legislation.

In cases of unfounded reports made in bad faith or with gross negligence, SANCO S.p.A. reserves the right to act in defence of its interests and to protect affected individuals.

SANCO S.p.A. has appointed an external committee of experts to handle whistleblowing reports.

These professionals specialize in whistleblowing legislation, organizational models pursuant to Legislative Decree 231/01, management systems, EU law, industrial relations, and labor law.

The committee operates with full autonomy, impartiality, and independence from any processes that could be subject to reporting.

Additionally, SANCO has made available a secure external digital platform, managed by a specialized third party, to ensure the effectiveness and confidentiality of the reporting process, and to provide broad, unrestricted access to all individuals wishing to submit a report.

While anonymous reports are accepted if thoroughly detailed, the Company encourages whistleblowers to provide identified (non-anonymous) reports to help streamline investigations and enhance their effectiveness.

To ensure the effectiveness of the whistleblowing process and provide broad, non-discriminatory access to all those wishing to make a report, SANCO S.p.A. has made available multiple alternative communication channels, including:

• Digital platform accessible at sancowhistleblowing.segnalazioni.eu
• Oral report by requesting a face-to-face meeting with the Whistleblowing Committee. This can be arranged by sending an email request (with read receipt) to: whistleblowing@cnvv.it These meetings may also take place outside of company premises.
• Registered mail with acknowledgment of receipt, addressed to:
  WHISTLEBLOWING COMMITTEE of CNVV – STRICTLY CONFIDENTIAL – Corso Cavallotti, 25 – 28100 Novara, Italy.

For reports submitted by post, two sealed envelopes must be used: the first envelope should contain the whistleblower’s identifying details and a copy of their ID.

The second envelope should contain the report itself, to keep the whistleblower’s identity separate from the contents of the report.

Both envelopes must be placed in a third sealed envelope, clearly marked on the outside as “confidential” and addressed to the report handler.

The report will be registered confidentially by the designated handler.

Monitoring of these communication channels is ensured by the Whistleblowing Committee, which should be contacted in the event of any technical issue.

The whistleblowing documentation of SANCO S.p.A. is available at the following links:

• Information Notice – Download PDF 
• Operating Procedure – Download PDF