{"id":11579,"date":"2026-03-26T12:22:35","date_gmt":"2026-03-26T11:22:35","guid":{"rendered":"https:\/\/stoneitaliana.com\/whistleblowing\/"},"modified":"2026-04-01T01:45:53","modified_gmt":"2026-03-31T23:45:53","slug":"whistleblowing","status":"publish","type":"page","link":"https:\/\/stoneitaliana.com\/en\/whistleblowing\/","title":{"rendered":"Whistleblowing"},"content":{"rendered":"\t\t
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Reporting Misconduct \u2013 Whistleblowing<\/h2>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
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<\/p>

The European Union, through Directive 2019\/1937, has updated the regulations concerning the protection of<\/p>

persons who report violations of Union law, in order to create a minimum standard for the protection<\/p>

of whistleblowers’ rights in all Member States. Italy has implemented the European Directive through Legislative Decree 10<\/p>

March 2023 No. 24.<\/p>

By adopting this Policy, STONE ITALIANA SPA has intended to comply with the aforementioned<\/p>

regulatory requirements, as well as the guidelines provided by ANAC in this regard.<\/p>

The objective pursued is to provide the whistleblower, i.e., the person reporting violations, with clear operational instructions<\/p>

regarding the subject, content, recipients, and methods of transmitting reports.<\/p>

The report management procedure guarantees the confidentiality of the reporting person’s identity from<\/p>

receipt and in every subsequent contact. Pursuant to Article 5, paragraph 1, letter e) of the Decree, this <\/p>

policy therefore provides information on the channels, procedures, and requirements for making internal<\/p>

and external reports.<\/p>

1.<\/b> <\/b>REPORTING PERSONS<\/b><\/p>

a) Reports may be made by the following persons:<\/p>

employees, including workers performing:<\/p>

– <\/span>part-time, intermittent, fixed-term, agency, apprenticeship, or accessory work<\/p>

(whose employment relationship is governed by Legislative Decree No. 81\/2015);<\/p>

– <\/span>occasional services (pursuant to Article 54-bis of Decree-Law No. 50\/2017, converted by Law No. 96\/2017);<\/p>

b) self-employed workers<\/p>

– with a contract for services (Article 2222 of the Civil Code);<\/p>

– with a collaboration relationship (pursuant to Article 409 of the Code of Civil Procedure), such as agency relationships, commercial representation<\/p>

and other collaboration relationships that result in a provision of continuous and coordinated work,<\/p>

predominantly personal, even if not of a subordinate nature;<\/p>

– with a collaboration relationship that results in exclusively personal work provisions,<\/p>

continuous and whose execution methods are organized by the client;<\/p>

c) d) e) collaborators who carry out their work activities with entities that provide goods or services or that <\/p>

carry out works on behalf of the Company;<\/p>

freelance professionals and consultants who provide their services at the Company;<\/p>

volunteers and trainees, paid and unpaid, who provide their services at the Company;<\/p>

STONE ITALIANA S.P.A.<\/p>

Via Lavagno, 213 \u2013 37040 Zimella \u2013 Verona Italy \u2013 Tel 39.0442 715715 \u2013 Fax 39.0442 715000 \u2013 stone@stoneitaliana.com<\/a> \u2013 http:\/\/www.stoneitaliana.com<\/a><\/p>

Share capital Euro 10,000,000 paid-in Euro 10,000,000 \u2013 Tax Code and Registration No. in the Verona Business Register 00684880230 \u2013 VAT No. IT00684880230<\/p>

1<\/span>SINCE 1979 SURFACE TECHNOLOGY AND DESIGN<\/p>

f) shareholders and persons with functions of administration, direction, control, supervision, or representation,<\/p>

even when such functions are exercised de facto at the Company (for example, members<\/p>

of the Board of Directors).<\/p>

The protection of reporting persons (Article 6 of this Policy) also applies when the report or<\/p>

public disclosure of information occurs in the following cases:<\/p>

a) when the legal relationship described above has not yet begun, if information about violations was<\/p>

acquired during the selection process or in other pre-contractual phases;<\/p>

b) during the probationary period;<\/p>

c) after the termination of the legal relationship if information about violations was<\/p>

acquired during the relationship itself.<\/p>

2.<\/b> <\/b>SUBJECT MATTER OF THE REPORT AND EXCLUDED REPORTS<\/b><\/p>

The reports indicated in the following table may be made:<\/p>

Number of employees Subject matter of the report<\/i><\/p>

with 50 or more<\/p>

employees<\/p>

– <\/span>European and national offenses (see below<\/p>

points a) and b) <\/p>

(Article 3, paragraph 2, letter a), Legislative Decree No. 24\/2023) <\/p>

In more detail, the violations indicated in the previous table may concern:<\/p>

a) violations of national or European provisions consisting of offenses concerning the following sectors:<\/p>

financial services, products, and markets and prevention of money laundering and terrorist financing; product safety<\/p>

and compliance; environmental protection; public health; protection of privacy and protection of personal data;<\/p>

security of networks and information systems;<\/p>

b) violations of European provisions consisting of: i) acts or omissions that harm the financial interests<\/p>

of the Union; ii) acts and omissions concerning the internal market; iii) acts and conduct that undermine <\/p>

the object or purpose of the provisions of Union acts in the sectors mentioned above;<\/p>

c) unlawful conduct relevant under Legislative Decree 231\/2001.<\/p>

STONE ITALIANA S.P.A.<\/p>

Via Lavagno, 213 \u2013 37040 Zimella \u2013 Verona Italy \u2013 Tel 39.0442 715715 \u2013 Fax 39.0442 715000 \u2013 stone@stoneitaliana.com<\/a> \u2013 http:\/\/www.stoneitaliana.com<\/a><\/p>

Share capital Euro 10,000,000 paid-in Euro 10,000,000 \u2013 Tax Code and Registration No. in the Verona Business Register 00684880230 \u2013 VAT No. IT00684880230<\/p>

2<\/span>SINCE 1979 SURFACE TECHNOLOGY AND DESIGN<\/p>

3.<\/b> <\/b>REPORTING CHANNELS: INTERNAL, EXTERNAL, PUBLIC DISCLOSURE<\/b><\/p>

The Company has established an internal reporting channel that guarantees the confidentiality of the identity of the<\/p>

reporting person, the person involved, and the person otherwise mentioned in the report, as well as the<\/p>

content of the report and related documentation.<\/p>

Please note that Whistleblowing<\/i><\/b> <\/i>reports must first be made using the internal channel.<\/p>

Reporting through the external channel, established and managed by ANAC, may only be made under certain<\/p>

conditions and public disclosure under even more stringent conditions, without prejudice to the possibility of<\/p>

filing complaints with the judicial authority.<\/p>

4.<\/b> <\/b>CONTENT AND METHODS OF SUBMITTING REPORTS<\/b><\/p>

A whistleblowing report<\/b> may be made when the following conditions are met:<\/p>

– <\/span>when one has information, including well-founded suspicions, concerning violations committed or that, based on<\/p>

concrete elements, may be committed, of national or European Union regulatory provisions<\/p>

that harm the public interest or the integrity of the Company, as well as concerning conduct aimed<\/p>

at concealing such violations<\/p>

and<\/p>

3<\/p>

– <\/span>such information was learned, or suspicions arose, within the work context.<\/p>

Reports concerning the following will not be considered:<\/p>

– <\/span>disputes, claims, or requests related to a personal interest of the reporting person;<\/p>

– <\/span>individual employment or collaboration relationships of the reporting person with the Company, or with hierarchically<\/p>

superior figures;<\/p>

– <\/span>aspects of the private life of the reported person, without any direct or indirect connection with<\/p>

company and\/or professional activities.<\/p>

Furthermore, the following reports are not permitted:<\/p>

– <\/span>pretextual, defamatory, slanderous reports or those aimed solely at harming the reported person;<\/p>

– <\/span>reports concerning violations that the reporting person knows are not well-founded.<\/p>

STONE ITALIANA S.P.A.<\/p>

Via Lavagno, 213 \u2013 37040 Zimella \u2013 Verona Italy \u2013 Tel 39.0442 715715 \u2013 Fax 39.0442 715000 \u2013 stone@stoneitaliana.com<\/a> \u2013 http:\/\/www.stoneitaliana.com<\/a><\/p>

Share capital Euro 10,000,000 paid-in Euro 10,000,000 \u2013 Tax Code and Registration No. in the Verona Business Register 00684880230 \u2013 VAT No. IT00684880230SINCE 1979 SURFACE TECHNOLOGY AND DESIGN<\/span><\/p>

Contents of the report<\/p>

The report, on pain of inadmissibility<\/b>, must contain:<\/p>

1. the identifying information<\/b> of the reporting person and contact details<\/b> to which subsequent updates may be communicated;<\/p>

2. a clear, complete, and detailed description of the facts<\/b> subject to the report;<\/p>

3. the circumstances of time and place<\/b> in which the fact subject to the report occurred and, therefore, a<\/p>

description of the facts subject to the report specifying details relating to circumstantial information and,<\/p>

where present, also the manner in which one became aware of the facts subject to the report;<\/p>

4. the personal details<\/b> or other elements that allow identification of the person(s) considered responsible for the<\/p>

reported facts;<\/p>

5. indication of any other persons<\/b> who may provide information about the facts subject to the report;<\/p>

6. indication of any documents<\/b> that may confirm the validity of such facts;<\/p>

7. any other information<\/b> that may provide useful confirmation of the existence of the reported facts.<\/p>

8. in the case of using the analog channel, an express declaration of wishing to benefit from whistleblowing<\/b><\/p>

protections<\/b>, e.g., by including the wording “confidential to the report handler.”<\/p>

Methods of reporting<\/p>

Whistleblowing<\/b> <\/i><\/b>reports<\/i> may be made using the following methods:<\/p>

upon request of the reporting person through a direct meeting with the Whistleblowing Management Office (Paola<\/p>

Dalla Valle and Annalisa Dalla Valle)<\/p>

through ordinary mail by placing the report in two sealed envelopes, including, in the<\/p>

first envelope, the identifying information of the reporting person together with an identity document;<\/p>

in the second envelope, the subject matter of the report with related documentation;<\/p>

both envelopes must then be placed in a third envelope bearing the wording<\/p>

“Confidential to the Report Handler” and addressed to the Whistleblowing Management Office of Stone<\/p>

Italiana spa.<\/p>

Anonymous reports<\/p>

Anonymous reports or reports from which it is not<\/b><\/p>

possible to determine the identity of the reporting person will not be considered.<\/b><\/p>

Anonymous reports will be registered by the report handler and retained.<\/p>

In any case, protective measures for the reporting person apply only if the reporting person is<\/p>

subsequently identified and has suffered retaliation.<\/p>

STONE ITALIANA S.P.A.<\/p>

Via Lavagno, 213 \u2013 37040 Zimella \u2013 Verona Italy \u2013 Tel 39.0442 715715 \u2013 Fax 39.0442 715000 \u2013 stone@stoneitaliana.com<\/a> \u2013 http:\/\/www.stoneitaliana.com<\/a><\/p>

Share capital Euro 10,000,000 paid-in Euro 10,000,000 \u2013 Tax Code and Registration No. in the Verona Business Register 00684880230 \u2013 VAT No. IT00684880230<\/p>

4<\/span>SINCE 1979 SURFACE TECHNOLOGY AND DESIGN<\/p>

Transmission of reports<\/p>

Whistleblowing reports must be sent to the Whistleblowing Management Office, in accordance with the<\/p>

adopted reporting channel.<\/p>

Please note that the receipt of reports is suspended during the Company’s closure period.<\/p>

5.<\/b> <\/b>REPORT MANAGEMENT<\/b><\/p>

This procedure regulates the process of receiving, analyzing, and handling reports of unlawful conduct<\/p>

of which the reporting person became aware within the work context.<\/p>

In managing the internal reporting channel, the report handler (hereinafter also the<\/p>

“handler” or “recipient”) operates as follows:<\/p>

Receipt of the report<\/p>

The recipient issues the reporting person an acknowledgment of receipt of the report within seven days<\/b> from the<\/p>

date of receipt. The acknowledgment will be sent to the contact details indicated by the reporting person and, if not indicated, the <\/p>

report will be archived.<\/p>

Anonymous reports are registered and their documentation is retained.<\/p>

The Company will archive reports received by ordinary mail through appropriate tools<\/p>

that ensure confidentiality (e.g., within archives protected by security measures).<\/p>

Oral reports – in the forms indicated in this Policy – are documented by the<\/p>

report handler who will prepare a record of the meeting that will be signed by both the handler and the<\/p>

reporting person, and a copy will be provided to the latter.<\/p>

Relations with the reporting person and supplementation of the report<\/p>

The recipient maintains communications with the reporting person and may request, if necessary, supplementation.<\/p>

In the case of a record prepared following a meeting with the reporting person, the latter may rectify the record<\/p>

of the meeting by signing it.<\/p>

Examination of the report<\/p>

The recipient follows up on received reports, assessing the existence of the reporting person’s standing and<\/p>

that the report falls within the scope of application of the regulation; this is followed by assessment of the circumstances of<\/p>

time and place in which the fact occurred.<\/p>

Following the preliminary verification:<\/p>

– <\/span>if the requirements are not met, the report is archived<\/b>, with reasons provided;<\/p>

reasons;<\/p>

– <\/span>if the requirements are met, an investigation<\/b> is initiated.<\/p>

STONE ITALIANA S.P.A.<\/p>

Via Lavagno, 213 \u2013 37040 Zimella \u2013 Verona Italy \u2013 Tel 39.0442 715715 \u2013 Fax 39.0442 715000 \u2013 stone@stoneitaliana.com<\/a> \u2013 http:\/\/www.stoneitaliana.com<\/a><\/p>

Share capital Euro 10,000,000 paid-in Euro 10,000,000 \u2013 Tax Code and Registration No. in the Verona Business Register 00684880230 \u2013 VAT No. IT00684880230<\/p>

5<\/span>SINCE 1979 SURFACE TECHNOLOGY AND DESIGN<\/p>

Investigation<\/p>

The recipient ensures the proper conduct of the investigation through:<\/p>

– <\/span>collection of documents and information;<\/p>

– <\/span>involvement of external parties (in the event that it is necessary to avail oneself of the technical assistance of<\/p>

third-party professionals) or other company functions, which have an obligation to cooperate with the report<\/p>

handler;<\/p>

– <\/span>hearing of any other internal\/external parties, where necessary.<\/p>

The investigation is conducted in accordance with the following principles:<\/p>

– <\/span>necessary measures are adopted to prevent identification of the reporting person and the persons<\/p>

involved;<\/p>

– <\/span>verifications are conducted by persons with the necessary training and activities are<\/p>

tracked and properly archived;<\/p>

– <\/span>all parties involved in the assessment maintain confidentiality of the information received, unless<\/p>

otherwise provided by law;<\/p>

– <\/span>verifications are conducted ensuring the adoption of appropriate measures for the collection, use,<\/p>

disclosure, and retention of personal information and ensuring that the needs of the investigation<\/p>

are balanced with those of privacy protection;<\/p>

– <\/span>appropriate measures are ensured to manage any conflicts of interest when the report<\/p>

concerns the recipient.<\/p>

Feedback to the reporting person<\/p>

Within three months<\/b> from the date of the acknowledgment of receipt or, in the absence of such acknowledgment, within three months from the expiration<\/p>

of the seven-day period from submission of the report, the recipient provides feedback regarding<\/p>

the report, communicating alternatively:<\/p>

– <\/span>archiving<\/b>, providing the reasons for the decision, or<\/p>

– <\/span>the validity<\/b> of the report and referral to the competent internal bodies for appropriate follow-up, or<\/p>

– <\/span>the activity carried out and still to be carried out (in the case of reports that require, for verification purposes,<\/p>

a longer investigation activity) and any measures adopted (measures taken or<\/p>

referral to the competent Authority).<\/p>

6.<\/b> <\/b>Conflict of interest<\/b><\/p>

If the report handler is in a conflict of interest, for example as a reported or<\/p>

reporting person, the report will be handled by the Administrative Manager \u2013 Dr. Soliman Luisa.<\/p>

STONE ITALIANA S.P.A.<\/p>

Via Lavagno, 213 \u2013 37040 Zimella \u2013 Verona Italy \u2013 Tel 39.0442 715715 \u2013 Fax 39.0442 715000 \u2013 stone@stoneitaliana.com<\/a> \u2013 http:\/\/www.stoneitaliana.com<\/a><\/p>

Share capital Euro 10,000,000 paid-in Euro 10,000,000 \u2013 Tax Code and Registration No. in the Verona Business Register 00684880230 \u2013 VAT No. IT00684880230<\/p>

6<\/span>SINCE 1979 SURFACE TECHNOLOGY AND DESIGN<\/p>

7.<\/b> <\/b>Protection of the reporting person and their liability<\/b><\/p>

Reporting persons may not suffer any form of retaliation. The law provides that those who make <\/p>

reports may not be sanctioned, demoted, dismissed, transferred, or subjected to other organizational measures<\/p>

that end up having, directly or indirectly, negative effects on working conditions,<\/p>

or effects of discrimination or retaliation against them.<\/p>

The reasons that induce a person to report or denounce or publicly disclose are irrelevant for purposes<\/p>

of their protection.<\/p>

In judicial or administrative proceedings, or even in out-of-court proceedings concerning<\/p>

the ascertainment of prohibited conduct against reporting persons, it is presumed that such conduct<\/p>

was carried out because of the report, public disclosure, or complaint to the judicial<\/p>

or accounting authority. The burden of proving that such conduct toward reporting persons is motivated by reasons <\/p>

unrelated to the report, public disclosure, or complaint rests with the person who carried them out.<\/p>

out.<\/p>

However, alleged discriminatory or retaliatory measures suffered must be communicated to ANAC, to which<\/p>

alone is entrusted the task of ascertaining whether the retaliatory measure is consequent to the reporting of misconduct and<\/p>

applying, in the absence of proof by the Company that the measure taken is unrelated to the report, an<\/p>

administrative pecuniary sanction.<\/p>

Processing of personal data. Confidentiality <\/p>

All processing of personal data will be carried out in accordance with Regulation (EU) 2016\/679, Legislative Decree<\/p>

June 30, 2003, No. 196 and Articles 13 and 14 of the Decree; furthermore, failure to comply with confidentiality obligations<\/p>

may result in disciplinary liability, without prejudice to any additional liability provided by<\/p>

law.<\/p>

The information notice regarding the processing of personal data following a whistleblowing report is<\/p>

available on company notice boards and on the website.<\/p>

Internal and external reports and related documentation are retained for the time necessary for<\/p>

processing the report and in any case no longer than 5 years from the date of communication<\/p>

of the final outcome of the reporting procedure, in compliance with confidentiality and personal data protection obligations.<\/p>

personal data.<\/p>

Liability of the reporting person<\/p>

The Company guarantees the reported person the right to be informed (within a reasonable period of time) regarding<\/p>

any reports that involve them, guaranteeing the right to defense where disciplinary proceedings are initiated against them.<\/p>

against them.<\/p>

This procedure also leaves unaffected the criminal and disciplinary liability of the<\/b><\/p>

reporting person in the event of slanderous or defamatory reports pursuant to the Criminal Code and Article<\/b><\/p>

2043 of the Civil Code.<\/b><\/p>

STONE ITALIANA S.P.A.<\/p>

Via Lavagno, 213 \u2013 37040 Zimella \u2013 Verona Italy \u2013 Tel 39.0442 715715 \u2013 Fax 39.0442 715000 \u2013 stone@stoneitaliana.com<\/a> \u2013 http:\/\/www.stoneitaliana.com<\/a><\/p>

Share capital Euro 10,000,000 paid-in Euro 10,000,000 \u2013 Tax Code and Registration No. in the Verona Business Register 00684880230 \u2013 VAT No. IT00684880230<\/p>

7<\/span>SINCE 1979 SURFACE TECHNOLOGY AND DESIGN<\/p>

Also sources of liability, in disciplinary proceedings and in other competent venues, are any forms of abuse<\/p>

of the whistleblowing reporting procedure, such as manifestly unfounded reports and\/or made<\/p>

solely for the purpose of harming the reported person or other parties, and any other instance of improper use or<\/p>

intentional instrumentalization of the procedure itself.<\/p>

8.<\/b> <\/b>Sanctioning system<\/b><\/p>

Regarding the sanctioning regime, ANAC applies the following administrative pecuniary sanctions:<\/p>

\u2022<\/span> from 10,000 to 50,000 euros when it ascertains retaliation, or that the report was obstructed or there was an attempt<\/p>

to obstruct it, or that the confidentiality obligation was violated;<\/p>

\u2022<\/span> from 10,000 to 50,000 euros when it ascertains that reporting channels have not been established, that<\/p>

procedures for making and managing reports have not been adopted, or that the adoption of such procedures<\/p>

is not compliant, as well as when it ascertains failure to verify\/analyze received reports;<\/p>

\u2022<\/span> from 500 to 2,500 euros against the reporting person, when their civil liability is ascertained,<\/p>

for willful misconduct or gross negligence, for defamation and slander.<\/p>

9.<\/b> <\/b>Entry into force and amendments<\/b><\/p>

This policy will enter into force on December 14, 2023. Upon its entry into force, all provisions previously <\/p>

adopted on the matter, in whatever form communicated, must be considered repealed, if<\/p>

incompatible or inconsistent, as they are replaced by the present provisions.<\/p>

The Company will provide the necessary publicity and post the policy on the company notice board.<\/p>

All employees may propose, when deemed necessary, reasoned additions to this policy; the<\/p>

proposals will be examined by the Company’s General Management.<\/p>

This policy remains subject to periodic review.<\/p>

Zimella, December 14, 2023 STONE ITALIANA SPA<\/p>

Rev.0<\/p>

STONE ITALIANA S.P.A.<\/p>

Via Lavagno, 213 \u2013 37040 Zimella \u2013 Verona Italy \u2013 Tel 39.0442 715715 \u2013 Fax 39.0442 715000 \u2013 stone@stoneitaliana.com<\/a> \u2013 http:\/\/www.stoneitaliana.com<\/a><\/p>

Share capital Euro 10,000,000 paid-in Euro 10,000,000 \u2013 Tax Code and Registration No. in the Verona Business Register 00684880230 \u2013 VAT No. IT00684880230<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t","protected":false},"excerpt":{"rendered":"

Reporting Misconduct \u2013 Whistleblowing The European Union, through Directive 2019\/1937, has updated the regulations concerning the protection of persons who report violations of Union law,…<\/p>\n","protected":false},"author":267191400,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"advanced_seo_description":"","jetpack_seo_html_title":"","jetpack_seo_noindex":false,"footnotes":""},"class_list":["post-11579","page","type-page","status-publish","hentry"],"jetpack_sharing_enabled":true,"jetpack_likes_enabled":true,"jetpack_shortlink":"https:\/\/wp.me\/PgY5s2-30L","_links":{"self":[{"href":"https:\/\/stoneitaliana.com\/en\/wp-json\/wp\/v2\/pages\/11579","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/stoneitaliana.com\/en\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/stoneitaliana.com\/en\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/stoneitaliana.com\/en\/wp-json\/wp\/v2\/users\/267191400"}],"replies":[{"embeddable":true,"href":"https:\/\/stoneitaliana.com\/en\/wp-json\/wp\/v2\/comments?post=11579"}],"version-history":[{"count":1,"href":"https:\/\/stoneitaliana.com\/en\/wp-json\/wp\/v2\/pages\/11579\/revisions"}],"predecessor-version":[{"id":11580,"href":"https:\/\/stoneitaliana.com\/en\/wp-json\/wp\/v2\/pages\/11579\/revisions\/11580"}],"wp:attachment":[{"href":"https:\/\/stoneitaliana.com\/en\/wp-json\/wp\/v2\/media?parent=11579"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}