In pursuing its business objectives, Logistica del Golfo firmly believes in ethical values, integrity and respect for people and the environment, and considers that an environment that facilitates open and transparent communication and exchange means protecting them. Logistica del Golfo therefore considers that every stakeholder, both inside and outside the company, has a fundamental role to play in ensuring an ethical, safe and responsible working environment: when something can be improved or when a situation does not comply with and is not in line with the company's principles and values, internal regulations or the law, it is a right and a duty to express this, without fear of retaliation or discrimination.
We encourage all interested parties (employees, customers, suppliers, etc.) to report any improvements that could be made or any discrepancies or anomalies that have been detected.
Two reporting channels have been identified:
1. Online communication: The reporting channel has been identified as a dedicated Whistleblowing Platform that the Company has made available and accessible at the following link: Reporting platform.
The Whistleblowing Platform is an IT tool that guarantees the confidentiality of the identity of the whistleblower, the person involved or mentioned, as well as the content of the report and related documentation. Furthermore, depending on the type of report, the platform allows the Supervisory Body (SB), as required by the 231 Organisational Model, or the QHSE office to communicate with the whistleblower, while guaranteeing their anonymity, and providing feedback on the action taken or intended to be taken in response to the report.
2. Paper communication: This method allows reports to be sent by post to the company's registered office or by hand to the relevant manager. To ensure confidentiality, reports must be placed in a sealed envelope marked “Riservata OdV” (Confidential to the Supervisory Body) on the outside.
For the purposes of managing the report, it is advisable that the reporting person provide, in good faith, any information that may be useful for conducting internal investigations, including, where available, supporting documentary evidence.
The person making the report may remain anonymous, but it may be useful to know their identity in order to carry out the checks. Their identity is ONLY known to the persons in charge who are legally bound to maintain confidentiality.
Anyone who reports a violation in good faith should not fear retaliation, as they will be protected by the Company and local legislation, where applicable. Logistica del Golfo guarantees protection from any act of retaliation against the reporting person for reasons directly or indirectly related to the report made in good faith. In any case, in order to protect the dignity, honour and reputation of everyone, the Company is also committed to offering maximum protection against defamatory reports. Furthermore, knowingly providing false or misleading information may result in disciplinary action.
Whistleblowing is a fundamental corporate tool through which employees, collaborators or individuals outside a company or organisation can report illegal activities. There are two main parties involved in a report: the whistleblower (literally, “the one who blows the whistle”) and the reported party, i.e. the company or public body that has potentially committed an offence against the whistleblower. The European Whistleblowing Directive No. 2019/1937, implemented in Italy through Legislative Decree No. 24 of 10 March 2023, provides for the adoption of new protection standards for whistleblowers.
Whistleblowing reports concern any act, behaviour, irregularity, or omission, committed or attempted, that harms the public interest or the integrity of the public administration or the Company.
By way of example, but not limited to, these include administrative, accounting, criminal or civil offences or unlawful conduct relevant to Legislative Decree 231/01, as well as the Organisation, Management and Control Model and company procedures.
It is important that the report is sufficiently detailed and specific so as to highlight the precise circumstances and facts. In particular, it is necessary to include: a clear description of the fact, indicating the time and place where it occurred; personal details or other information that allows the person(s) to whom the reported facts can be attributed to be identified; the identification of persons with knowledge of the facts; an indication of possible sources of evidence; and the manner in which the fact came to light.
Anonymous reports will still be accepted if they contain detailed facts, but the persons making the reports will not receive notification that the matter has been taken up or communication of the outcome of the investigation.
Complaints related to the personal interests of the whistleblower, concerning their individual employment relationships or relationships with superiors or colleagues (e.g. requests for salary increases, commercial complaints, etc.) do not fall within the above category of whistleblowing. Also excluded from the scope of whistleblowing are reports that are clearly unfounded, information that is already in the public domain, and information obtained on the basis of unreliable rumours.
Therefore, any reports linked to the personal interest of the whistleblower are not considered whistleblowing reports and may be treated as ordinary reports, where provided for by the competent internal bodies of the Company.
Through the platform described in the section ‘How to report’, you can submit a whistleblowing report in complete confidentiality.
Ordinary reports are reports that do not fall within the scope of whistleblowing reports. By way of example, reports may relate to:
• Health and safety in the workplace: accidents, near misses, unsafe behaviour, unsafe conditions;
• Environment: chemical spills, environmental near misses, waste dumping;
• Quality: various complaints, packaging or transport methods, behaviour of company personnel not covered by whistleblowing.
You can submit a standard report via the platform described in the section entitled “How to report”.
All reports received are accepted and treated with the utmost seriousness and confidentiality. Specifically appointed individuals, who are independent of the Company where necessary, will manage the report, analysing it and carrying out the necessary investigations.
Specifically, once the report has been received, the validity of the circumstances described therein will be verified, in accordance with the principles of impartiality and confidentiality, carrying out any activities deemed appropriate.
The reporting party may be asked to provide further information regarding the report.
If the report contains unsubstantiated and/or unverifiable information and the reporting party is unable to provide the necessary additional information, the report will be archived.
If the content of the report is confirmed, the Manager will refer the matter to the relevant departments to determine any necessary measures.
Logistica del Golfo undertakes to provide feedback on the follow-up to the report, while protecting the confidentiality of the persons involved, within 90 days of receipt of the report.
