Whistleblowing

1. What is Whistleblowing? How is it implemented?

In compliance with Article 4, paragraph 1 of Legislative Decree No. 24 of 10 March 2023, implementing EU Directive 2019/1937 on Whistleblowing C.S.E. S.R.L. has implemented an Internal Reporting Channel which, by guaranteeing the confidentiality of the whistleblower’s identity, the content of the report, and any documentation attached to it, allows employees, collaborators, consultants, and other categories of persons identified under Article 2 of the aforementioned Legislative Decree 24/2023 to report unlawful conduct learned of in connection with their employment or collaboration relationships.
The platform used, in line with the aforementioned regulatory provisions, guarantees the confidentiality of the data entered into the portal, including through the use of encryption tools.

2. How to submit a report

C.S.E. S.R.L. has set up a reporting system compliant with current Whistleblowing legislation.

Anyone wishing to report a violation or suspected violation of the Code of Ethics is invited to act in good faith, using one of the tools made available by the company.

Report via the online platform (recommended channel)

C.S.E. provides a dedicated reporting platform, based on the open-source software GlobaLeaks, available at:

🔗 whistleblowing.cseservizi.it

The platform allows a report to be submitted, even completely anonymously, ensuring the protection of the whistleblower’s identity and the confidentiality of the content through encryption. The system also allows you to:

• receive a personal receipt code to track the status of your report;
• communicate anonymously and bidirectionally with the Reports Manager, even after the initial submission;
• attach supporting documents to the report in complete security.

GlobaLeaks is an open-source tool compliant with EU Directive 2019/1937, the General Data Protection Regulation (GDPR), and the ISO 37002 standard, and is therefore fully suited to the confidentiality and security requirements set out under Italian whistleblowing legislation.

Report by oral request

You may request a direct meeting with the Reports Manager by sending a request to: whistleblowing@cseservizi.it

Report by ordinary mail

Where possible, the reporting party should prepare two separate envelopes:

• First envelope: identifying details of the reporting party and a copy of an identification document
• Second envelope: detailed description of the alleged violation

Both envelopes should be placed inside a third envelope, to be sent to:

Comitato Etico presso C.S.E.
Via dalle Mura Sud 45
54100 Massa (MS)

Report by email

The report may be sent, even anonymously, to: whistleblowing@cseservizi.it

All reports received will be handled by C.S.E. with the utmost confidentiality and care.

External ANAC channel

The reporting party may at any time contact the external channel managed by ANAC (the Italian National Anti-Corruption Authority), pursuant to Article 6 of Legislative Decree 24/2023, in the following cases:

1. The internal channel has not been activated, or does not comply with the decree
2. There is reasonable ground to believe the internal report did not receive adequate follow-up
3. There is well-founded fear of retaliation
4. The violation directly concerns the Reports Manager or the Sole Director

🔗 Whistleblowing – Modulo per la segnalazione di condotte illecite ai sensi del D.Lgs. 24/2023