Whistleblowing
With Legislative Decree N. 24 10th 2023, the Italian legal system has implemented Directive (EU) 2019/1937 concerning the protection of persons who report violations of the European Union law (Whistleblowing Directive).
In accordance with Legislative Decree No. 24/2023, Btinkeeng has established an internal channel for the collection and management of warning notice, which the purpose of ensuring the confidentiality of the whistleblower identity, the person involved in the report, and the related documentation.
Btinkeeng has adopted a procedure that outlines the operational guidelines for using the channel, managing warning notice, and the protective measures available to individuals protected by the regulation.
Who can make warning notice?
It can come from different kind of subjects, including employees, self-employed individuals, collaborators, freelancers, consultants, volunteers and interns (even if unpaid), suppliers, shareholders, or people with functions of administration, management, control, supervision, or representation, even de facto.
What can be reported?
Warning notices, which must be as detailed as possible, should concern violations included within the scope of Article 2 of Legislative Decree n. 24/2023. The regulation defines ‘violations’ as behaviors, acts, or omissions that may harm the public interest or the integrity of the company concerned by the report, of which the reporting individuals have become aware in the context of their work. Warning norices outside the objective scope of application of the regulation will not be considered.
How to proceed with the warning notice?
It must be sent through the specific IT application. Please consult the procedure for further details on how to submit reports.
Access the application through the following link:
Who manages the warning notice?
The management of the internal reporting channel and the verification of the procedure and eligibility of the report are delegated to an internal Whistleblowing Committee. This committee, in accordance with the timelines specified by the regulations, examines the reported facts ensuring confidentiality and objectivity, including the potential hearing of the whistleblower and other involved parties. For this purpose, the Committee may be supported by external consultants or by the competent company departments.
External reporting channel and public disclosure
Whistleblowers, as a last resort and only in specific circumstances listed in the procedure, may use an external reporting channel managed by ANAC, available at the website https://www.anticorruzione.it/-/whistleblowing
Whistleblowing procedure is attached.