Whistleblowing Procedure

How do I report an offense or behavior that I believe to be improper?

Privacy information & Complete procedure

When you become aware that someone within TEF Bridge is not behaving according to the rules, engaging in unlawful conduct pursuant to Legislative Decree 231 of 2001, or violating the Organizational Model adopted by the company, you must report it to the Supervisory Body.

The report can be made to the Supervisory Body in written or oral form.

Written form:

• PEC MAIL – address: whistleblowing.tefbridge@legalmail.it, by attaching the reporting form or by filling out the FORM directly from the website
• Regular mail to TEF Bridge S.r.l. – Via Giovanni Durando 39 Milan, Italy 20158, IT.
  The report must be submitted inside a sealed envelope which, together with a further envelope containing the identifying details of the reporting person, must be placed inside a third sealed envelope marked ‘Confidential – for the attention of the Supervisory Board (OdV)’.

Oral form:

Request for oral hearing.

The rights of the whistleblower

To protect the reporter-and incentivize reporting:

• Confidentiality regarding your identity is guaranteed (except in cases strictly necessary and required by law);
• Protection measures are in place (prohibition of retaliation and limitations of liability).
• The whistleblower protection measures are applied when, at the time of reporting.
• The whistleblower had reasonable grounds to believe that the information about the violations was true and fell within the objective scope of the whistleblowing legislation.
• The protective measures against the whistleblower do NOT apply when the whistleblower’s criminal liability for defamation or slander is ascertained, even by a first-instance judgment, or his civil liability for the same reason, in cases of willful misconduct or gross negligence.

To do

• Respect the rules and procedures to properly perform your duties.
• If you see, learn of, or suspect that someone is not behaving according to the rules, contact the Supervisory Board and report it.
• If you believe a rule is incorrect or slowing down operations, share your impressions with your supervisor before taking any action.

Not to do

• When faced with others’ failure to follow a rule, keep your mouth shut and do your own thing.
• When your direct manager asks you to make exceptions to procedures or instructions… because that way we’ll be better… do it because the boss asks you to.
• If you feel a procedure or rule isn’t correct or slows down work too much, change it and do your own thing.
• Modify or disregard certain steps in procedures so the company benefits.