Whistleblowing

Ethical and Protected Reporting at LOGO

LOGO SpA promotes a corporate culture based on ethics, transparency and accountability, guided by the core values that define our organisation: integrity, innovation, health, safety, environmental protection, teamwork, reliability, respect, trust, ethical conduct and long-term stability.

Accordingly, LOGO has adopted an organisational model in compliance with Italian Legislative Decree 231/2001, and has established a dedicated channel through which reports can be submitted to the Supervisory Body regarding conduct not compliant with company standards, whether by employees or third parties. Such conduct may involve breaches of laws or regulations, the Code of Ethics and Conduct, the Organisational Model 231, or other internal rules and procedures in force at LOGO. This reporting channel is not intended for commercial complaints or matters relating to personal interests.

Through the responsible participation of employees and external stakeholders who report potential misconduct, the company is able to promptly identify irregularities and take the necessary corrective measures.

Who can submit a whistleblowing report?

Anyone can submit a report, including anonymously. This includes employees, former employees, job applicants, partners, customers, suppliers, consultants, collaborators, shareholders and, more generally, anyone with a legitimate interest in LOGO’s business activities.

For a report to be properly assessed, it must contain sufficient and specific information. This means that the report should include enough detail to allow the facts to be verified. Relevant details may include: the identity of the individuals involved, the context in which the events occurred, the place and time period of the events, as well as any documentation or evidence supporting the claims. Full instructions on how to prepare and submit a report are available in the policy attached here.

How to submit a report

Reports can be submitted directly to the Supervisory Body using the form below.

Anyone who receives a report through other channels, whether written or verbal, must promptly forward it to the Supervisory Body within seven days of receiving it. The report must be transmitted through the usual communication channels used with the Supervisory Body, while also informing the reporting person (if known) that the report has been forwarded and ensuring strict confidentiality.

How reports are handled

Reports are received by LOGO’s Supervisory Body, which may involve the relevant internal departments if further investigation is required.

Within 10 days of receiving the report, an acknowledgement of receipt will be provided, and within three months of that acknowledgement, feedback will be provided on the action taken or planned in response to the report.

Confidentiality and protection

Legislative Decree No. 24 of 10 March 2023 (implementing EU Directive 2019/1937 on Whistleblowing) introduced a unified framework governing reporting channels and the safeguards granted to whistleblowers in both the public and private sectors.

The reporting person, any facilitators and any individuals involved in the report are guaranteed full confidentiality. In the case of anonymous reports, the identity of the reporting person cannot be traced.

Any form of personal or professional retaliation in response to a report is strictly prohibited and will not be tolerated. If you believe you have suffered retaliation as a result of submitting a report, you may notify the National Anti-Corruption Authority (ANAC) through the dedicated page on its website.

All personal data is processed in accordance with applicable data protection legislation.

Reports to the National Anti-Corruption Authority (ANAC) through an external channel

If, after submitting a report, you do not receive an acknowledgement of receipt and/or feedback, or if you have reasonable grounds (based on real circumstances and verifiable information) to believe that: the internal report will not be properly addressed, the report may lead to retaliation, or the violation represents an immediate or clear threat to the public interest, you may submit a report directly to ANAC. The ANAC website also provides a list of Third Sector organisations that offer support to whistleblowers, including free information, assistance and advice on how to submit reports and how to protect against retaliation.

Submit a report

If you wish to remain anonymous, please describe the situation you are reporting as clearly and in as much detail as possible. If you are comfortable doing so, we encourage you to provide your contact details, enabling further in-depth investigation of the report. Your anonymity will still be protected, as reports are received by an independent third-party body separate from LOGO.

By submitting a report, you are helping to prevent illegal or unethical conduct within the organisation. You are acting responsibly and should not fear retaliation, threats or any violation of your rights.

Thank you for your cooperation. Your contribution is extremely valuable to us.