Reporting Violations To The Oversight Board (Whistleblowing)

WHAT IS IT

With this whistleblowing policy, any employee or third party can report any problem related to non-compliance with our Code of Ethics, Organizational Model, Anti-Corruption Policy or with ISSEL NORD’s company procedures. The best way to send a report is to include your name, in order to help any verification of the facts and the collection of further information. The reporting system adopted by ISSEL NORD is in compliance with the requirements of the Law no. 179/2017 (“Whistleblowing Law”).

WHAT TO SAY

Here some illustrative, although incomplete, examples of possible reports:

conflict of interest cases unknown to the company;
corruption attempt of a third part towards any employee or of any employee towards a third party;
fraud;
inappropriate use of the company assets;
intentional communication of false information to a Public Administration.

Any reports of an ambiguous nature, or not detailed, or clearly made in bad faith, or with slanderous and libelous content will not be taken into account. Any report not in the responsibility of the Oversight board will be addressed to the competent functions.

HOW TO SAY

You can send your report to:

Mail address:
ISSEL NORD S.R.L.
Via Trieste 4, 19020 Follo (SP)
Riservato Organismo di Vigilanza
Online platform: it is possible to send reports with or without registration. The platform is a channel adequate to ensure the confidentiality of the data entered by the whistleblower, in compliance with the requirements of the Law no. 179/2017 (“Whistleblowing Law”).
Use the following button to access the platform.

Whistleblowing

SAFEGUARD RULES

The Company guarantees the utmost confidentiality as far as the source and the information provided are concerned, except when legally required. ISSEL NORD will avoid retaliation of any kind (disciplinary sanctions, downgrading, suspension, lay-off) as well as any discrimination to those Company employees who, in good faith, report events or situations connected to compliance with our Code of Conduct, Organizational Model, Anticorruption Policy, Company procedures and legal regulations.

Right of access: (Article 15 of the Regulation)	confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, the right to obtain, among other things, access to your personal data and information regarding the purposes of the processing, the categories of personal data concerned and the recipients or categories of recipient to whom the personal data have been or will be disclosed.
Right to rectification: (Article 16 of the Regulation)	(i) rectification without undue delay of inaccurate personal data concerning you and (ii) completion of your personal data, where incomplete.
Right to erasure («right to be forgotten»): (Article 17 of the Regulation)	erasure of personal data concerning you without undue delay (the Data Controller has the obligation to erase personal data without undue delay in the cases set out in Article 17 of the Regulation).
Right to restriction of processing: (Article 18 of the Regulation)	restriction of processing in the cases set out in Article 18 of the Regulation.
Right to data portability: (Article 20 of the Regulation)	receipt in a structured, commonly used and machine-readable format of personal data concerning you; the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, in the cases set out in Article 20 of the Regulation.
Right to object for processing carried out under Article 6(1)(e) or (f): (Article 21 of the Regulation)	right to object, at any time, on grounds relating to your particular situation, to processing of personal data concerning you based on point (e) or (f) of Article 6(1), including profiling based on those provisions.