PLC S.p.A. adopted its first version of the Organisation, Management and Control Model on 14 March, 2011, which was later updated 2016.
Subsequently, PLC S.p.A. owing to organisational changes, resulting from its corporate restructuring, and also due to the introduction of additional types of offenses under Legislative Decree 231/01, updated and supplemented its Organisation, Management and Control Model following a resolution passed by the Board of Directors on 11 October, 2019.
In particular, the Organisation, Management and Control Model of PLC S.p.A. includes:
In order to facilitate the supervisory activity regarding the effectiveness of the Organisation, Management and Control Model, in accordance with the currently applicable law, PLC S.p.A. has established that any violation or suspected violation of the 231/01 Model and/or any other information pertaining to the implementation of the Organisation, Management and Control Model, may be reported, in accordance with the provisions of current legislation, to the Supervisory Body, through the following reporting channels:
The PLC Group has always been particularly focused to the prevention of risks that could compromise the responsible and sustainable management of its business. For this reason PLC S.p.A. has prepared the “Whistleblowing” procedure ("Procedure") for its employees and third parties.
Whistleblowing is the reporting system with which anyone who wishes can contribute to highlighting risks and / or situations potentially harmful to PLC S.p.A. such as fraud, generic risk or a potentially dangerous situation, by sending a specific report.
The ultimate goal of whistleblowing is to manage any reports in order to identify any problems that could arise from significant corporate misconduct pursuant to Legislative Decree 231/01.
The Procedure was approved by the Board of Directors of PLC S.p.A. and regulates, also through operational indications, the process of sending, receiving, analysing, processing and managing reports of misconduct, pursuant to Legislative Decree 231/01, as well as of the violations of the relevant Model 231/01, transmitted by the whistleblower. The Procedure also governs the ways of protecting the whistleblower’s confidentiality, shielded from any retaliation for having made the report.
The Procedure applies to any report made by any person (employee or third party) through the appropriate communication channels indicated below, which guarantees their confidentiality.
The reports must be made in good faith and can be made anonymously, in the latter case it is necessary that the report is described in detail.
The Supervisory Body of PLC S.p.A. is responsible for managing reports, through the following reporting channels:
The Procedure falls within the scope of the internal control and risk management system tools adopted by the PLC group to fight corruption, ensure fairness and transparency in the conduct of business and the activities carried out, and protect its position and reputation.
Whistleblowing is, therefore, a further and important part of the PLC Group's internal control and risk management system.