Whistleblowing

WHAT IS WHISTLEBLOWING?

THE RULES AT A GLANCE FOR “WHISTLEBLOWING”

How to make complaints
Complaints may be made by:
• whistleblowing platform (platform is available on the side in the Links section);
• email to segnalazioni@saes-group.com

What to complain
Complaints of any behavior by anyone in Saes which may constitute, by way of example but not limited to:
• violation of laws and regulations;
• violations of the Code of Ethics, Supplier Code of Conduct, Anti-corruption Code and Code of Business Conduct;
• violations of workplace health or safety, violation of environment law, violation of human rights, etc.

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 the General Counsel who has 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 individuals subject to the complaints may be involved or notified of this activity but in no case will proceedings be brought merely due to the complaint, in the absence of concrete findings with regard to its content.

Protection of whistleblower
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 guarantees the anonymity of the whistleblower.
Sanction may be applied against anyone who implements or threatens to implement acts of retaliation against those who have submitted complaints as part of this policy or against those who, with wilful intent or gross negligence, have made complaints that are found to be groundless.

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.

POLICY WHISTLEBLOWING
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".
The "Whistleblowing Policy" is available on the side in the Links section.

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://3mwpfwv5xejtpadf.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/projects/torbrowser.html