WHISTLEBLOWING REPORTING PATHWAY
Edison provides employees, business partners, vendors and other parties with an opportunity to report instances of corruption, fraud or other nonconforming conduct through the use of an online guided pathway that assists the reporting party and makes it possible to document the report in a precise and orderly manner.
The objective pursued with the adoption of this tool is to prevent the occurrence of nonconforming or irregular conduct within the organization, while at the same time involving all stakeholders and the public in general in an activity aimed at contrasting illegality through active and responsible participation. However, communications regarding commercial activities (e.g., complaints about utility bills, invoicing, etc.) must be channeled through the customer service tools provided for this purpose.
HOW AND WITH WHOM REPORTS SHOULD BE FILED
Clicking on the whistleblowing banner provides access to a reporting pathway physically located on a third-party server. Noncompliance reports are received by the Manager of the Internal Auditing Department and the Manager of the Corporate Compliance & Ethics Function within the abovementioned Department, who undertake to handle the report in a confidential manner and not to disclose the identity of the reporting person without his consent. The personal data that may be present are processed in compliance with the current Privacy legislation and kept for the period of time strictly necessary for the management of the report. It is possible to open a dialogue with the signaling person that allows to complete the report with indirect assistance via the IT platform. This tool is flanked and integrates the other methods (e-mail address and traditional mail) provided for sending an alert, also pursuant to Legislative Decree 231/2001.
WHY FILE A NONCONFORMITY REPORT
Often, employees and other parties are in a position that makes them aware of nonconforming or irregular conduct that the Company in unable to identify on a timely basis; it is therefore important that it be given an opportunity to verify and possibly correct these anomalies.
Responsible reports of nonconformity, filed in good faith and in the common interest can allow the Company to promptly intercept and remedy and correct unlawful conduct and irregular acts of corruption, fraud or other nonconforming conduct that constitute violations of the Company’s Code of Ethics and are damaging to the Company and possibly other parties.
PROTECTION OF THE REPORTING PARTY
Putting oneself on the line to expose or denounce corruptive conduct can give rise to practical as well as psychological problems. This modality accepts nonconformity reports filed anonymously. A properly filed report, documented and detailed, can be handled without any further involvement of the reporting party. In any event, information will always be handled on a confidential basis. There are two type of protection for the reporting party: operational protection and technological protection.
OPERATIONAL PROTECTION
As mentioned above, nonconformity reports are handled on a confidential basis and the identity of the reporting party, if provided, is not revealed without his/her consent.
TECHNOLOGY USED
As for technological security and the traceability of the reporting party, the Company chose to use an extensively tested technological platform already implemented in social whistleblowing contexts characterized by a high level of personal risk: Globaleaks, an open source software developed by Hermes Center for Transparency and Digital Human Rights that makes it possible to dialog anonymously with the reporting party without the recipient or other parties being able to trace the origin of the nonconformity report.
PROTECTION OF THE PARTY SUBJECT OF A NONCONFORMITY REPORT
During activities to verify and ascertain possible instances of nonconformity, the parties subject of nonconformity reports may be involved in or informed of such activities; however, under no circumstance shall proceedings be initiated solely due to a nonconformity report, absent concrete verification of the report’s content.
This could potentially occur based on other evidence discovered and verified as a result of the nonconformity report.
WHISTLEBLOWING POLICY
By clicking on “continue”, the reporting party declares that he/she is cognizant of and agreed with the content of the policy governing the use of the whistleblowing tool made available by Edison (the Whistleblowing Policy document can be downloaded from this internet page in pdf format).
CLICKING ON CONTINUE
