Whistleblowing – RWM Italia S.p.A.
The principles of good corporate governance include, in particular, the elements of adherence to the rules in operational conduct and the protection of employees.
In order to make this possible, modern whistleblower systems must be installed which are available to all employees throughout the Rheinmetall Group and also to external parties, so that suspicious events can be reported.
International whistleblower systems are an indispensable pillar of any modern Compliance Management System (CMS). Employees and also external persons such as business partners are thus given the opportunity to report compliance violations without having to reckon with personal sanctions.
For this purpose, Rheinmetall has created several ways of reporting a compliance violation. The whistleblower is thus free to choose how he or she wishes to report his information to Rheinmetall.
RWM Italia S.p.A. has always been particularly attentive to the prevention of risks that could compromise an ethical and sustainable management of its business and, consistently with its mission and its internal control system, to the possibility of knowing critical situations and correcting them by consolidating the relationship of trust with the stakeholders.
To this end, it has set up specific internal channels to receive reports of violations of internal or external policies, to guarantee the correctness and transparency in the conduct of businesses carried out and to protect the company's position and image, such as fraud, or a generic risk or a potentially dangerous situation, also guaranteeing compliance with the regulatory provisions set out in Legislative Decree no. 24 of 10 March 2023 on whistleblowing and containing "Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 concerning the protection of persons who report violations of Union law and containing provisions concerning the protection of persons which report violations of national regulatory provisions" (hereinafter the "WB Decree"), as well as the indications provided by the ANAC.
Reporting of any misbehavior that could represent a fraud attempt or that could represent a risk to colleagues and shareholders or that constitute an act of illicit nature to the interests and reputation of the company itself, can be an effective form of combating to corruption, if appropriately regulated.
The whistleblowing channels are designed to guarantee the confidentiality of the identity of the whistleblower and the content of the, to protect the "reporter", as well as the "reported person" and the people involved, through secure protocols and encryption tools that allow you to protect personal data and information, including the ones eventually attached to the report, as well as to be able to address the problems reported promptly in accordance with specific internal guidelines (“Procedura di Whistleblowing").
In compliance with the regulatory provisions regarding whistleblowing, it is possible to report, even anonymously, violations falling within the cases described below (by way of example and not exhaustively):
- administrative, accounting, civil and/or criminal offences
- significant illicit conduct pursuant to Legislative Decree 231/01
- violations of the Code of Ethics, the Code of Conduct of the Rheinmetall Group, the Organization, Management and Control Model 231/01 and the internal policies and procedures of RWM Italia S.p.A.
- offenses that fall within the scope of application of European Union or national acts relating to the following sectors:
public procurement; financial services, products and markets and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; protection of privacy and protection of personal data and security of networks and information systems - acts or omissions concerning the market
- acts or omissions that damage the reputation of RWM Italia S.p.A.
All personal data will be processed in accordance with the “Informativa Privacy Whistleblowing”, in full respect of the current Privacy Regulations (meaning EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 relating to the protection of natural persons with regard to the processing of personal data, as well as the free movement of such data (GDPR), Legislative Decree no. 196/2003, Legislative Decree no. 101/2018 as well as any other legislation on the protection of personal data applicable in Italy, including the provisions of the Guarantor), with particular regard to the confidentiality of the identity of the subjects involved and for the security of the processing also in accordance with the provisions of the WB Decree.
The whistleblowing regulation, as described above in respect to the reporting channels and the protections provided for the Whistleblower and the Reported Party, also applies to foreign companies in compliance with local legislation.
In this regard, it is specified that the transfer of personal data of subjects coming from third countries is permitted pursuant to and within the limits of the law applicable in the individual case.
The whistleblowing procedure aims to define unique methods and intervention times for carrying out internal and external reports (ANAC channel).
RWM Italia S.p.A. therefore encourages anyone who becomes aware of violations (behavior, acts or omissions) of the law or of internal company protocols which are, even potentially, harmful to the public interest or the integrity of the Company, to make a report via the channels reported on this page and in the Whistleblowing Procedure.
