Whistleblowing

What is whistleblowing?


How to make complaints

Complaints may be made by:


What to complain

Complaints of different types of conduct, violations and offenses (e.g., administrative, accounting, civil or criminal offenses, violations of the Organization and Control Model ex. Legislative Decree 231/2001 – if implemented -, violation of EU regulations). For more details, please refer to the Whistleblowing Procedure.


Content of complaints

Complaints must be made in good faith and must be detailed with precise information (e.g. place, time, subjects involved, description of the facts, etc.).

Whistleblower may decide not to provide the personal details, as the complaint may also be made entirely anonymously.


Who receives the complaints

Complaints are received by individuals expressly authorized for this purpose, autonomous, trained and dedicated to receiving and handling reports (including SAES Getters’ Legal & Compliance Director) who have the right, depending on the needs, to involve other competent company functions.


Right of reported person

During the verification and assessment activity of any non-compliance, the persons reported may be heard but in no case will proceedings be brought merely due to the complaint, in the absence of concrete findings with regard to its content.

In addition, until the conclusion of the proceedings, the same guarantees of confidentiality accorded to the reporting person and the persons involved in or named in the reports are extended to them.


Protection of whistleblower and other individuals deserving protection (e.g. facilitators)

SAES prohibits acts of retaliation or discrimination, of any nature, direct or indirect, against the whistleblower for reasons linked, directly or indirectly, to the complaint and ensures confidentiality regarding the content of the complaint and the identity of the whistleblower; if requested, guarantees also the anonymity of the whistleblower.

SAES will consider taking appropriate measures and appropriate action against anyone who implements or threatens to implement acts of retaliation against those who have submitted complaints as part of Whistleblowing policy or against those who, with wilful intent or gross negligence, have made complaints that are found to be groundless.The same protection is also provided for other persons deserving protection as identified in the applicable legislation.


Technology used (Whistleblowing platform reporting)

Access to the Whistleblowing platform (external to the site and to the SAES network) is possible via the company website and is subject to the “no-log” policy (access is not tracked in any way even if carried out within the company network).

Globaleaks, open-source and free software, is in fact created to allow the launch of safe and anonymous whistleblowing initiatives. The software is developed by the Hermes Center for Transparency and Digital Human Rights.


Whistleblowing Policy

By clicking on “Make your complaint“, the whistleblower will be redirected to an external site and declares to have read and accepted the contents of the “Whistleblowing Policy“, included the Privacy Information Notice.

Please read the above procedure carefully for more details and, in any case, before formulating and sending the complaint.

Complaints made via the online platform are encouraged which facilitate and allow greater detail in the presentation of the facts by filling in a pre-set questionnaire. The platform also has the advantage of establishing a “dialogue” between the reporting party and the receiving party in the field of reporting management, in complete confidentiality.

The system is also accessible via Tor at the address: http://d55gjl4mnvx4amcinc2wr4mkhi2yvyn3xypkjskyezbkpkufaalqiuqd.onion

The Tor browser cannot be downloaded on SAES PCs.
To access via Tor, it is therefore necessary to download a specific browser to your home PC (by way of example) available at the following link:
https://www.torproject.org/download/