Pengo S.P.A. Whistleblowing

Who can submit a report?
Anyone who witnesses an offence or irregularity attributable to persons linked to Pengo SpA can submit a report, including employees, former employees and job position applicants, shareholders, customers, partners, suppliers (also contractors/subcontractors), non-employed workers or professionals in a business relationship with the aforementioned entity, freelancers, consultants, agents and intermediaries, volunteers and interns (paid and unpaid), and anyone who is a legitimate stakeholder of Pengo SpA.


What can be reported?
Any behaviour, act or omission committed, or based on concrete elements, may be committed or undertaken, including those of an omissive nature, with the aim of concealing said breaches.
Information referable to staff Pengo SpA and/or third parties regarding breaches of legislation, regulations and the system of procedures in force at the company, can be reported.
This does not include commercial complaints, claims or requests linked to personal interests.


How to submit a report
The report must be adequately detailed, i.e. contain a sufficient degree of detail, at least in abstract form, to enable the identification of precise and concurrent facts referable to specific contexts, as well as of elements useful for the purpose of verifying the truthfulness of the report, including: (i) the description of the reported fact; (ii) natural persons or entities involved; (iii) the period in which the fact occurred; (iv) the circumstances in which the reporting person came into the knowledge of the fact and (v) Any other persons or entities that can report the fact and relevant general information on the matter. Reports must be sent using the special channels indicated in this Brochure and defined in greater detail in the Company Procedures adopted by Pengo SpA, with preference whenever possible for the web channel, which ensures the reporting person's confidentiality by computerized means.

Anonymous report
Pengo SpA will examine all received reports, including anonymously submitted ones, except for those that make it difficult or impossible to contact the anonymous reporting person to request their cooperation and receive additional information that is necessary or useful for the verification of reported facts.


How the report is managed
A person or entity identified by Pengo SpA (the Manager) runs a preliminary check of received Reports to ascertain whether investigative activities should be undertaken on the described facts, verifies the truthfulness thereof and provides a response to this effect, so that suitable measures can be adopted by competent bodies.

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Whistleblowing

What is whistleblowing
Italian Legislative Decree no. 24 of 10 March 2023, implementing (EU) Directive 2019/1937 on whistleblowing introduced a uniform regulation of whistleblowing channels and the protections afforded to whistleblowers in the public and private sectors, to which Pengo SpA has also adapted.
The term Whistleblowing refers to the institution that protects those who, within the context of the organization they belong to, report irregularities or situations of hazard or risk that may cause harm to the entity or third parties.


Who can submit a report?
Anyone who witnesses an offence or irregularity attributable to persons linked to Pengo SpA can submit a report, including employees, former employees and job position applicants, shareholders, customers, partners, suppliers (also contractors/subcontractors), non-employed workers or professionals in a business relationship with the aforementioned entity, freelancers, consultants, agents and intermediaries, volunteers and interns (paid and unpaid), and anyone who is a legitimate stakeholder of Pengo SpA.


What can be reported?
Any behaviour, act or omission committed, or based on concrete elements, may be committed or undertaken, including those of an omissive nature, with the aim of concealing said breaches.
Information referable to staff Pengo SpA and/or third parties regarding breaches of legislation, regulations and the system of procedures in force at the company, can be reported.
This does not include commercial complaints, claims or requests linked to personal interests.


How to submit a report
The report must be adequately detailed, i.e. contain a sufficient degree of detail, at least in abstract form, to enable the identification of precise and concurrent facts referable to specific contexts, as well as of elements useful for the purpose of verifying the truthfulness of the report, including: (i) the description of the reported fact; (ii) natural persons or entities involved; (iii) the period in which the fact occurred; (iv) the circumstances in which the reporting person came into the knowledge of the fact and (v) Any other persons or entities that can report the fact and relevant general information on the matter. Reports must be sent using the special channels indicated in this Brochure and defined in greater detail in the Company Procedures adopted by Pengo SpA, with preference whenever possible for the web channel, which ensures the reporting person's confidentiality by computerized means.

Anonymous report
Pengo SpA will examine all received reports, including anonymously submitted ones, except for those that make it difficult or impossible to contact the anonymous reporting person to request their cooperation and receive additional information that is necessary or useful for the verification of reported facts.


How the report is managed
A person or entity identified by Pengo SpA (the Manager) runs a preliminary check of received Reports to ascertain whether investigative activities should be undertaken on the described facts, verifies the truthfulness thereof and provides a response to this effect, so that suitable measures can be adopted by competent bodies.

Confidentiality and prohibition of retaliatory acts
Pengo SpA is committed to ensuring the utmost confidentiality with reference to persons, entities and facts in the report as well as the reporting person's identity. Retaliatory actions against the Reporting Person are forbidden; therefore their demotion, dismissal, suspension, transfer, or in general any other company measures that negatively impact their working conditions are not permitted.


Unlawful reports
Unlawful reports are those that are unfounded, prepared in bad faith or with serious negligence. In such cases, Pengo SpA reserves the right to act in the defence of its interests and protect unfairly reported persons or entities.


Personal data processing
I Data will be processed in compliance with applicable personal data protection legislation. Information on the purposes and methods of Data processing by Pengo SpA is available on the web platform at the address provided here below and/ or on the company website.

SPECIFIC CHANNEL FOR REPORTING

Login to web platform

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