Whistleblowing

We encourage our people to speak up

Italtel has always been committed to pursuing every business decision in full compliance with applicable laws and the principles set forth in its Code of Ethics.

Italtel intends to operate within these principles, in particular by combating corruption by all means and acting in all circumstances with loyalty, integrity, and honesty in order to maintain and increase the esteem and respect of its stakeholders and be a successful, competitive, healthy, and sustainable company.

The Whistleblowing system created by Italtel is designed to collect reports of potential wrongdoing or irregularities that have come to light in the course of work and is intended to promote a culture of ethics and legality when witnessing irregular conduct.

The system is intended for employees of the Italtel Group and for all those who, in general, operate, in Italy or abroad, on behalf of or for the benefit of the Group or who have business relationships with the latter through any type of contract or assignment.

Reportable events must generally concern a reasonable and legitimate suspicion or good faith awareness of unlawful conduct or irregularities in the workplace that could harm the integrity of the Italtel Group, such as violations of the Code of Ethics, acts that could constitute crimes or cause financial or reputational damage, or violations of internal regulations or procedures. Therefore, reports should not be based on rumors, hearsay, or personal complaints.

All personal data relating to reports will be processed in accordance with current data protection legislation, meaning EU Regulation 2016/679 (GDPR) as well as any other applicable Italian legislation, in full respect of the fundamental rights and freedoms of the individuals involved, with particular regard to the confidentiality of their identity and the security of the processing.

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FAQ

Anyone can submit a report to Italtel; in addition to employees in Italy or abroad, anyone who works on behalf of or for the benefit of the Italtel Group or who maintains business relationships through any type of contract or assignment (collaborators, consultants, agents, intermediaries, interns, etc.).

Reports must generally concern information, including reasonable suspicions, regarding violations committed in the context of work activities that could harm the integrity of the Company or the Group. Such reports must relate to:

  • violations of the Organization, Management and Control Model pursuant to Legislative Decree 231/2001
  • Violations of the Code of Conduct (discrimination, harassment, conflict of interest, etc.)
  • administrative, accounting, civil or criminal offenses;
  • violations of internal provisions or procedures subject to disciplinary action;
  • in general, facts that may constitute crimes or cause damage (financial or image) to the Company or the Group.

They should not be reported and, in any case, will be ignored by the system:

  • disputes, claims or requests related to a personal interest that pertain exclusively to one’s individual employment relationships;
  • facts based on “rumour” or “hearsay”.

The following channels can be used to send internal reports:

  • Whistleblowing Web Portal

accessible via the dedicated section on the company intranet or via the Company website ( https://www.italtel.com/it/about/whistleblowing / )

The web portal is the primary and preferred reporting channel adopted by the Company. This channel guarantees, also through the use of encryption tools, the confidentiality of the identity of the whistleblower, and any persons mentioned in the report, as well as the content of the report and related documentation.

  • Email addresses

comitato_etico@italtel.com

Access to the mailbox is permitted exclusively to members of the Ethics Committee expressly authorized to manage reports, in compliance with appropriate technical and organizational measures aimed at ensuring the confidentiality, integrity, and security of the personal data processed.

  • Telephone number

+39 02 4388 2421

Those wishing to report verbally can call the aforementioned telephone number, which is answered by the Head of the Internal Audit function.

Italtel does not provide the option of recording verbal reports. The content of the telephone conversation will be transcribed and shared with the whistleblower. The whistlebower can verify, correct, and confirm the content of the transcript by signing it.

The report may also be made through a direct conversation between the whistleblower and the recipient of the report, identified as the Head of Internal Audit. In this case, the report may be transcribed in full in a written report; in such circumstances, the reporting person may verify, correct, and confirm the content of the report by signing it.

The whistleblower may also file an external report to ANAC if she/he has already filed an internal report through the Whistleblowing system described in this procedure and has not received a response, or has reasonable grounds to believe that the report is not being effectively followed up or may result in a real risk of retaliation.( https://www.anticorruzione.it/-/whistleblowing#p0 ).

 

The report must contain information that allows the bodies responsible for analyzing and processing the report to conduct appropriate checks to verify its validity. The report must therefore contain a description of the facts (including places and dates), the persons involved, and any names of other persons who can provide information. It may also include attachments (documents, photos, audio and video recordings).

Italtel prohibits and does not tolerate any form of retaliation or direct or indirect discrimination against the whistleblower for reasons directly or indirectly related to the report. Disciplinary action will be taken against those responsible for such forms of retaliation or discrimination.

If the report is found, due to the whistleblower’s intent or gross negligence, to be unfounded and manifestly defamatory towards the person involved, the whistleblower will be subject to disciplinary measures or sanctions pursuant to the applicable contracts.

Yes, anonymous reports can be submitted. Italtel will consider such reports if the information provided is sufficiently detailed to reveal facts and situations that can be investigated.

The reports are received, analyzed, verified and processed by the Italtel Ethics Committee made up of the General Counsel and Chief Compliance Officer and the heads of the Human Resources and Internal Auditn functions.  If you believe that one of the members of the Ethics Committee is involved in any way in the report, or if you deem it necessary or even appropriate to exclude one of these members from handling the report, you can highlight this circumstance within the web portal, which will automatically block the sending of information and notifications to the indicated member.

Absolutely. You can receive ongoing feedback on the progress of your report using the unique code provided to you by the web portal when you opened the report.

Regulations

Legislative Decree no. 24 of 10 March 2023 “Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons reporting breaches of Union law and laying down provisions regarding the protection of persons reporting breaches of national legislation”

Legislative Decree No. 231 of June 8, 2001, “Regulations of the administrative liability of legal entities, companies, and associations, including those without legal personality, pursuant to Article 11 of Law No. 300 of September 29, 2000”

Italtel Code of Ethics

Italtel S.p.A. Organization, Management and Control Model pursuant to Legislative Decree 231/2001 and subsequent amendments.

European Regulation 2016/679 – GDPR (General Data Protection Regulation) of 27 April 2016

Legislative Decree 30 June 2003, n. 196 “Personal Data Protection Code” as subsequently integrated and amended

ANAC Guidelines – “Guidelines on the protection of persons reporting violations of Union law and the protection of persons reporting violations of national regulatory provisions – Procedures for the submission and management of external reports” Approved with Resolution No. 311 of 12 July 2023 and subsequent amendments .

Provision of the Italian Data Protection Authority, no. 304 of 6 July 2023 regarding the ANAC Guidelines

Provision no. 581 of the Italian Data Protection Authority of 9 October 2025, containing its opinion on the draft “Guidelines on Whistleblowing on Internal Reporting Channels” and the resolution amending and supplementing the ANAC Guidelines on Whistleblowing.

Confindustria Operational Guide on the new Whistleblowing regulations, updated May 2026.

Privacy Notice

Whistleblowing System

Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”)

Italtel S.p.A., with its registered office at Via Caldera 21, 20153 Milan (hereinafter “Italtel” or the “Company”), acting as the Data Controller, informs you that personal data collected within the scope of the whistleblowing system are processed in compliance with applicable personal data protection legislation and the provisions of Legislative Decree no. 24/2023.

The following definitions apply:

  • violation – conduct, act, or omission that harms the public interest or the integrity of the Company;
  • report – a written or oral communication of information regarding violations, submitted via the internal reporting channels of the Company’s Whistleblowing system;
  • reporting person – the person submitting a report regarding violations obtained within the context of their work at the Company;
  • reported person (or involved person) – the person identified in the report as the individual to whom the violation is attributed or as someone otherwise implicated in the reported violation;
  • mentioned person – the person identified in the report as someone who might provide information regarding the reported violation but is not implicated in it.

1. Who this notice applies to

This notice applies to personal data processed during the management of whistleblowing reports and concerns:

  • the reporting person;
  • the involved or reported person;
  • persons potentially mentioned in the report;
  • the facilitator assisting the reporting person;
  • individuals benefiting from the protection measures provided for by Legislative Decree no. 24/2023, such as family members, colleagues, and other persons connected to the reporting person in the cases prescribed by law.

2. What data we process

Personal data contained in the report and related documentation may be processed, such as:

  • identification and contact details;
  • information regarding the employment or professional relationship;
  • information on the reported facts and the individuals involved;
  • any documents attached to the report.

Personal data that are manifestly irrelevant to the processing purpose—as indicated in paragraph 3 below—will not be collected or, if collected inadvertently, will be deleted without delay.

3. Purposes for which we use the data

Personal data are processed exclusively to:

  • receive and manage reports;
  • carry out necessary preliminary investigations;
  • adopt any corrective, disciplinary, or legal measures;
  • ensure the protection of the reporting person and other individuals protected by applicable regulations;
  • comply with legal obligations.

4. Legal basis for processing

Personal data processing is carried out to comply with obligations under Legislative Decree 24/2023, Legislative Decree 231/2001, and applicable personal data protection regulations, as well as to safeguard the Company’s integrity by addressing violations—or the effects thereof—that could cause harm to the Company.

5. How reports may be submitted and data processed

Your personal data will be processed using manual, electronic, and/or digital tools—which ensure the security and confidentiality of the data—strictly in connection with the processing purposes.

In particular, reports may be submitted via:

  • the whistleblowing platform;
  • the dedicated e-mail address;
  • the telephone channel managed by the Internal Audit function;
  • a direct meeting with the Head of the Internal Audit function.

6. Who may access the data

Personal data are processed exclusively by individuals who are expressly authorized and bound by confidentiality obligations. In particular, access to the data is granted to:

  • members of the Ethics Committee;
  • the Head of Internal Audit for the preliminary handling of oral reports;
  • the Supervisory Body in the cases provided for by the procedure;
  • any consultants or suppliers supporting the management of the system, provided they are duly authorized or appointed as data processors;
  • competent authorities in cases provided for by law.

The data will not be disseminated.

7. Confidentiality and protection of the whistleblower

Italtel adopts technical and organizational measures designed to guarantee the confidentiality of the identity of the whistleblower, the person involved, and other parties protected under whistleblowing regulations, in accordance with applicable law.

8. Data retention period

Personal data and documentation relating to reports are retained for the time necessary to handle them and, in any event, for no longer than five years following the communication of the final outcome of the reporting procedure.

9. Rights of data subjects

You may at any time exercise the rights to the Data Controller provided for in Articles 15 to 22 of the GDPR, within the limits set out in Article 2-undecies of Legislative Decree 196/2003 (Privacy Code).

Indeed, to further protect the whistleblower, Art. 2-undecies, paragraph 1, letter f) of the Privacy Code stipulates that the rights of data subjects (referred to in Articles 15 to 22 of the GDPR) may not be exercised via a request to the Data Controller or by lodging a complaint with the Italian Data Protection Authority (Art. 77 of the GDPR) if the exercise of such rights could result in actual and concrete prejudice “to the confidentiality of the identity of the person reporting violations of which they became aware by virtue of their employment relationship or the functions performed […]”.

In such cases, the Data Controller will assess the data subject’s requests in compliance with applicable regulations and the safeguards provided for by Legislative Decree 24/2023.

10. Contact details

For any request regarding the processing of personal data or to exercise the rights provided for by the GDPR, you may contact:

Italtel S.p.A.

Via Caldera 21, 20153 Milan

Data Protection Officer (DPO)

dpo@italtel.com

You also retain the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).

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Whistleblowing procedure

System for reporting work-related breaches – Collection, verification and treatment of reports

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Send a report

Our whistleblowing system ensures that any concerns or misconduct can be reported securely and confidentially. We are committed to protecting whistleblowers and thoroughly investigating all reports to maintain a transparent and accountable work environment. Your voice is crucial in helping us uphold our values and improve our operations. Submit your report with confidence, knowing that it will be handled with the utmost care and discretion.

 
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