WHISTLEBLOWING MANAGEMENT
Software Design (hereinafter also “SD”), aware of the importance of the process of preventing irregularities that may harm the public interest or the integrity of the Company, is committed to ensuring the highest standards of transparency, integrity and reliability.
To this end, it has provided a system for managing reports of unlawful conduct that may constitute or result in a violation of laws and regulations, the Organization, Management and Control Model pursuant to Legislative Decree 231/2001 adopted by the Company, the Code of Ethics, the Anti-Corruption policy and, more generally, corporate provisions.
Who can report?
Individuals working in the Company’s working environment, as:
– employees;
– self-employed workers;
– collaborators, freelancers and consultants;
– volunteers and interns, paid and unpaid;
– shareholders and persons with functions of administration, management, control, supervision or representation.
How can a report be made?
SD provides a plurality of alternative channels among them, specifically:
– electronic mail, at the e-mail address: odvsegnalazioni@sita.aero
– regular mail, at the address Software Design srl – Organismo di Vigilanza 231 -Aeroporto di Capodichino -Viale F. Ruffo di Calabria snc – 80144 Napoli
– IT platform, which can be accessed by clicking on the link below (“Enter your report here”): the system allows the submission of reports both in written and oral form, through an online guided path without the obligation to register or declare one’s personal data.
The Report must be circumstantiated, precise and verifiable, i.e., made with a sufficient degree of detail to allow the reported facts to be ascertained, and include at least the following elements: a description of the reported fact and the individuals (natural or legal persons) involved.
Although anonymous reports are accepted, named reports are preferred for the benefit of the speed and effectiveness of investigations, as well as for the purpose of the possible need for a suitable dialogue with the Whistleblower.
Receipt and management of the whistleblowing report
The management and verification of the merits of the circumstances represented in the report are entrusted to the Supervisory Board, which does so, in accordance with the principles of impartiality and confidentiality, carrying out any activity deemed appropriate. If, at the outcome of the verification, the report turns out not to be manifestly unfounded, the Supervisory Board, in relation to the nature of the violation, may forward the report to the Board of Directors of Software Design and to the shareholder SITA for the relevant fulfillments of competence.
The Supervisory Board, in carrying out the activities within its competence, may avail itself of the collaboration of its chosen personnel, who will be subject to the same confidentiality constraints and responsibilities to which the Board is subject.
For reports sent via web platform, management will see the involvement not only of the Supervisory Board but also of the Sita team in charge of the specific issue. Information flows (e.g., notifications to the reporter) will follow the procedures provided by the platform.
All personal data will be processed in accordance with current Privacy regulations, with regard for the confidentiality of the identity of the individuals involved also in accordance with the provisions of Decree No. 24/2023 (Whistleblowing). Information regarding the purposes and methods of personal data processing by SD is available here.
Prohibition of retaliatory acts
With respect to the whistleblower there is a prohibition of discrimination, no form of retaliation or discriminatory measures, direct or indirect, affecting working conditions for reasons directly or indirectly related to the whistleblowing is allowed or tolerated. Discriminatory measures include unjustified disciplinary actions, harassment in the workplace, and any other form of retaliation that results in intolerable working conditions. It is understood that the Company may take the most appropriate disciplinary and/or legal measures to protect its rights/assets and image, against anyone who has made, in bad faith, false or unfounded reports, for the sole purpose of slandering, defaming or causing prejudice to the reported person or other persons mentioned in the report.
