Whistleblowing

Whistleblowing is the system for reporting, protecting, and safeguarding individuals who disclose violations of national or European Union regulations that harm the public interest or the integrity of a public administration or private entity, which they have become aware of in a work-related context.

The E. Alemagna Preschool, in compliance with the obligations set out in Legislative Decree 24/2023, has adopted a specific Regulation for the management of reports of unlawful conduct (whistleblowing) and the protection of the whistleblower.

• Whistleblower: the natural person who reports information on violations acquired in the course of their work context.

• Reported Person (or Person Involved): the subject (natural or legal person) against whom the reported violation is attributed by the whistleblower.

A Report by the Whistleblower

MAY concern the following conduct:

• Unlawful acts committed in violation of EU legislation listed in Annex 1 to Legislative Decree 24/2023 and all national provisions implementing it. These include, in particular, violations in the following sectors: public procurement; financial services, products and markets, and the prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; protection of privacy and personal data; and the security of networks and information systems.

• Acts or omissions harming the financial interests of the European Union (Article 325 TFEU – combating fraud and illegal activities affecting EU financial interests) as defined in EU regulations, directives, decisions, recommendations, and opinions.

• Acts or omissions related to the internal market that undermine the free movement of goods, persons, services, and capital (Article 26(2) TFEU). This includes violations of EU rules on competition and State aid, corporate taxation, and mechanisms aimed at obtaining a tax advantage that defeats the object or purpose of the applicable corporate tax legislation.

• Acts or conduct that undermine the object or purpose of EU provisions in the sectors protected under Legislative Decree 24/2023.

MAY NOT concern:

• Irregularities in the management or organization of activities (maladministration).

• Disputes, claims, or requests connected to a personal interest of the whistleblower or of a person who has filed a complaint with the judicial or accounting authority, relating exclusively to individual employment relationships, including relations with hierarchical superiors (e.g., labor disputes, discrimination among colleagues, etc.).

• Reports of violations already mandatorily governed by EU or national acts listed in Part II of the Annex to Legislative Decree 24/2023, or national acts implementing the EU acts listed in Part II of the Annex to Directive (EU) 2019/1937, even if not mentioned in Part II of the Annex to Legislative Decree 24/2023.

• Reports of violations concerning national security, as well as procurement involving defense or national security aspects, unless such aspects fall within the relevant EU secondary law.

Reports Must Be Submitted by One of the Following Methods:

• Written Report via Postal Service: by paper letter in a sealed envelope addressed to Whistleblowing Committee, E. Alemagna Preschool, Via Don B. Parietti, 8 – 21020 Barasso (VA), marked “confidential and personal” with no sender indicated.

• Oral Report: via telephone lines or voice messaging systems, or by requesting a direct meeting with the Committee, to be scheduled within ten (10) days.