Whistleblowing - Kardia EN

WHISTLEBLOWING – INTERNAL PROCEDURE

Pursuant to the laws in place, especially the Legislative Decree no. 24 of 2023, Kardia established an external online platform where it is possible to submit, even anonymously, reports about criminal, civil, administrative or accounting offences, as well as violations of the Organization, Management and Control Model pursuant to the Legislative Decree no. 231 of 2001 and the Ethics Code (Company – Kardia EN), able to damage the public or the Company’s interests, arising in a work-related context, provided that the violations are not about the reporter’s personal interests and their own relationship with the Company only.

It is possible to submit reports for:

Employees (also during the trial period);
Self-employed workers and contractors;
Company’s suppliers’ employees and contractors;
Professionals and consultants of the Company;
Volunteers and interns, both paid and unpaid, working for the Company;
Shareholders and people in charge of managing, controlling and supervising duties, including legal representatives;
Candidates and potential suppliers.

Kardia ensures full protection of the whistleblowers, including:

Keeping confidential their identity and the matter of the report, as well as the reported people’s identity and third parties’ reputation in case the report is found to be false. This is one of the main reasons why the above-mentioned platform is the best instrument to submit the reports, as it is appropriately built to protect that kind of information. The whistleblower’ identity will be kept confidential and their data will be accessible to only to the person in-charge of managing the report, unless the whistleblower itself explicitly agrees to its sharing or this becomes necessary during a legal cause;
Protection of the whistleblowers from any retaliation stemming directly or indirectly from the reports submitted, impacting the relationship between Kardia and the whistleblowers.

Moreover, in the reports’ management process personal data will be treated according to the laws in place (EU Regulation no. 679 of 2016 and Legislative Decree no. 196 of 2003, as amended by Legislative Decree no. 101 of 2018). Reports’ related documents and data will be stored only for the strictly necessary period of time, in any case no more than 5 years from the last communication of feedback on the procedure.

Submitting a report needs reliability and good faith, and only in case of well-founded reasons to believe that the information about the violation is true.

In case the report submitted is intentionally false, the whistleblower can be sued for slander or defamation, and punished with a disciplinary fine.

The report can be submitted:

There is not a minimum content to be included in the report, but it is very important to include as many elements as possible in order to make internal investigations easier.

By 7 days from the submission, the whistleblower will receive a confirmation by the person in charge of the report. By 3 months from such confirmation, the whistleblower will receive a feedback; during such period of time, also further information can be asked.

In the above-mentioned procedure is not followed, or the whistleblower believes that the using the internal channel of communication is not effective or could lead to retaliation, it is possible to use the external channel of communication at ANAC: Whistleblowing – www.anticorruzione.it