Whistleblowing Platform of ER TLC Srl
In compliance with Legislative Decree No. 24/2023 and Legislative Decree No. 231/2001, ER TLC Srl has adopted a secure and confidential system for the receipt and management of reports. We believe in listening to and protecting people: anyone who submits a report is always protected, treated with respect, and never exposed to retaliation.
To ensure simple and secure access for employees, contractors, suppliers, third parties, and stakeholders, several communication channels are available.
Reports may be submitted through the following channels:
1. External whistleblowing channel, managed by an independent company:
*The identity of the reporting person is not disclosed to ER TLC, and all communications are filtered by an independent third-party company, which guarantees anonymity and confidentiality.
2. By sending a report by ordinary post, ensuring that the envelope is marked: “For the attention of the Whistleblowing Reports Officer – strictly confidential” and addressed to the company’s registered office.
3. By using the anonymous reporting box available at ER TLC’s operational office.
4. External reporting channel (ANAC) and public disclosure
The ways in which the reporting person may submit an external report to ANAC are defined directly by the Authority and are set out on its institutional website, in a dedicated section: https://www.anticorruzione.it.
It is also permissible to proceed by way of public disclosure, pursuant to Article 15 of Legislative Decree No. 24/2023, where at least one of the following conditions applies:
- the reporting person has submitted an internal report and an external report, or has made an external report directly, without receiving feedback within the statutory time limit (90 days) regarding the measures envisaged or adopted in response to the report;
- the reporting person has reasonable grounds to believe that the breach may constitute an imminent or manifest danger to the public interest;
- the reporting person has reasonable grounds to believe that the external report may give rise to a risk of retaliation or may not be effectively followed up, in view of the specific circumstances of the case, for example where there is a risk of concealment or destruction of evidence.
Persons making reports benefit from the protections provided for under Legislative Decree No. 24 of 10 March 2023, including confidentiality, protection against retaliation, and impartial handling of the report.
What may be reported
- Suspected or actual acts of corruption
- Breaches of the Code of Ethics or company policies
- Discriminatory acts or conduct detrimental to personal dignity
- Physical, moral, or psychological harassment
- Breaches relating to social accountability matters (SA8000)
- Breaches relating to gender equality matters (UNI/PdR 125)
ER TLC guarantees
- Absolute confidentiality of the identity of the reporting person, where disclosed
- A total prohibition on retaliation or discrimination
- Independent and impartial handling of reports
- Protection of personal data in accordance with the GDPR
- Careful and respectful handling of every report
Reports are assessed with due care, recorded confidentially and, where necessary, made the subject of an internal investigation, in full compliance with the law and the applicable regulations, and in accordance with the obligations to communicate with the reporting person within the time limits established by law (Article 5 of Legislative Decree No. 24/2023).