Whistleblowing Management Procedure 

Cremonesi Workshop S.r.l. has adopted a whistleblowing management process, including the possibility of submitting anonymous reports, aimed at preventing unlawful acts, irregularities, or misconduct carried out in violation of the Organisation, Management and Control Model pursuant to Legislative Decree no. 231/2001, the Anti-Bribery & Corruption (ABC) Management System, the FS Group Code of Ethics, as well as internal and/or external regulations (e.g., anti-corruption, antitrust, etc.), or any conduct potentially damaging or harmful, even reputationally, to the FS Italiane Group.

This whistleblowing process is an integral part of the Organisation, Management and Control Model pursuant to Legislative Decree no. 231/2001 of FS S.p.A., in compliance with Law no. 179/2017 (so-called Whistleblowing Law).

Who can report and what to report

Who Can Submit a Report

Reports can be submitted by:

  • Employees, freelancers, collaborators, volunteers, and interns (even unpaid) who perform their work within FS Group companies;

  • Workers or collaborators employed by entities that supply goods or services or carry out works in favour of third parties;

  • Freelancers and consultants working with FS Group companies;

  • Shareholders and individuals holding administrative, management, supervisory, or representative roles in FS Group companies.

Reports must refer to information about violations acquired in the context of the whistleblower’s work activities.

They may also be submitted:

  • Before the legal relationship begins, if the violation information was obtained during selection or pre-contractual phases;

  • During a probationary period;

  • After the termination of the relationship, if the information was acquired during the course of the relationship.

Cremonesi Workshop S.r.l. encourages whistleblowers to disclose their identity, which will be kept confidential as per current regulations, in order to facilitate the verification of the reported facts and keep the whistleblower informed of the outcomes. Anonymous reports are nonetheless accepted.

What to Report

Reports should concern facts (of any kind, including omissions) relating to FS Group personnel or third parties that may involve:

  • Violations of the 231 Models of FS Group companies, their implementing procedures, the Anti-Corruption Policy and ABC System, the Code of Ethics, or internal corporate rules and/or any conduct potentially damaging or harmful to the FS Italiane Group;

  • Administrative, accounting, civil, or criminal offences;

  • Unlawful conduct relevant under Legislative Decree no. 231/2001;

  • Violations of EU acts and corresponding national legislation;

  • Acts or omissions harming the EU’s financial interests;

  • Acts or omissions related to the internal market (e.g., competition or State aid violations);

  • Acts or conduct that undermine the purpose or effect of EU provisions.

Reports must be made in good faith and refer to facts the whistleblower believes to be true at the time of reporting. They must also be submitted promptly to enable proper verification.

The following do not qualify as whistleblowing:

  • Personal grievances, complaints, or claims exclusively related to the whistleblower’s individual work relationship or hierarchical issues;

  • Customer service-related complaints or commercial matters.

 

Reporting Channels 

Internal Reporting Channels

Reports can be sent to the Ethics Committee and/or Supervisory Body of Cremonesi Workshop S.r.l. using the following methods:

  • Ordinary mail:
    Cremonesi Workshop S.r.l.
    Technical Secretariat of the Ethics Committee
    Via Cefalonia 70, 25124 Brescia (BS), Italy

  • Email:

  • Verbal report:
    Via a formal statement made by the whistleblower during a dedicated hearing with the Ethics Committee or Supervisory Body, documented in minutes and signed by the whistleblower.

External Reporting and Public Disclosure

Legislative Decree no. 24/2023 allows for external reports to the National Anti-Corruption Authority (ANAC) and public disclosure in specific, legally defined cases, such as:

  • When no internal reporting channel exists or is non-compliant;

  • When a prior internal report received no follow-up;

  • When there are reasonable grounds to believe an internal report would not be effective or might trigger retaliation;

  • When the violation presents an imminent or evident threat to the public interest.

 

Protection of the Whistleblower

In compliance with applicable law, Cremonesi Workshop S.r.l. guarantees:

  • The confidentiality of the whistleblower’s identity from the moment the report is received;

  • The prohibition (and sanction, where possible) of any retaliatory or discriminatory measures—whether direct, indirect, actual, attempted, or threatened—against the whistleblower or associated persons (e.g., relatives, colleagues, employers, or entities connected to the whistleblower).

To ensure long-term protection, employees of Cremonesi Workshop S.r.l. who report misconduct will have their professional situation monitored for two years following the report.

All individuals involved in handling reports are legally bound to maintain confidentiality regarding the existence, content, and outcome of the report, as well as the identity of the whistleblower.

The whistleblower will receive:

  • Acknowledgment of receipt within 7 days of the report;

  • Information on the outcome of any investigation conducted.

 

Protection of involved persons

FS Group companies also protect the rights of the individuals involved in the report by ensuring that all communications regarding their identity follow the “need to know” principle: access is granted only when necessary for performing specific job duties.

The involved person is informed of the report’s existence and content, and receives a copy (excluding the identity of the whistleblower, unless disclosure is legally required).

They are also informed of the investigation's outcome. This notification may be delayed or withheld if public authority actions are pending or if disclosure could compromise the whistleblower’s confidentiality.

 

Process

Reports are directed to the Ethics Committee and/or the Supervisory Body of Cremonesi Workshop S.r.l.

The Supervisory Body is responsible for managing reports concerning:

  • Violations or attempts to circumvent the company's 231 Model;

  • Breaches of the Code of Ethics relevant under Legislative Decree no. 231/2001.

Investigations to verify the validity of the reported facts are conducted by the Internal Audit function of FS Sistemi Urbani S.p.A.
 

Click here to view the Whistleblowing Data Protecion Notice