General whistleblowing notice – Legislative Decree 24/2023
This notice is addressed to all individuals who interact with Atis S.r.l. and are entitled to report any corporate misconduct they are directly involved in or have become aware of.
Its purpose is to clearly and concisely inform potential whistleblowers about the reporting channel made available under Legislative Decree 24/2023, its operating mechanism, procedural steps, response timelines, and the company’s compliance with legal provisions.
The notice is made available to interested parties through:
- Publication on the website www.atismanipolatori.com accessible to external parties and Atis S.r.l. employees
- Posting on the company bulletin board.
The channels provided by the relevant legislation are:
- Internal (within the work context);
- External (ANAC);
- Report to judicial or accounting authorities.
To encourage the use of the internal channel, Atis S.r.l. provides employees and external stakeholders with the channels listed in the dedicated “Whistleblowing Procedure,” whose revision status is indicated in the document itself (also published on the company website).
Reporting by Mail
If using the paper channel by mail, the whistleblower must submit a written report (report form available for download on the website www.atismanipolatori.com) addressed to:
Attn: Whistleblowing Manager – Via Trento, 112-114 – 38017 Mezzolombardo (TN)
with the indication “Whistleblowing – CONFIDENTIAL/PRIVATE”
The whistleblower may use the forms available on the website.
Reporting by Email
If the whistleblower chooses to use email, they must send all required information to: whistleblowing@atismanipolatori.com, as specified in the dedicated procedure.
Both paper and electronic correspondence will be opened exclusively by the formally appointed Whistleblowing Manager. In addition to a confidentiality obligation imposed by the role, the designated person must strictly adhere to the safeguards designed to ensure the whistleblower’s confidentiality.
External Channel (ANAC)
Whistleblowers may use the external channel (ANAC) when:
- No internal reporting channel is required within the work context, or it is not active or compliant with legal requirements;
- An internal report has already been made but was not followed up;
- The whistleblower has reasonable grounds to believe that an internal report would not be effectively followed up or could lead to retaliation;
- The whistleblower reasonably believes the violation poses an imminent or obvious threat to the public interest.
Reporting methods are detailed on the ANAC website
https://www.anticorruzione.it/-/whistleblowing#p3
Report to Judicial or Accounting Authorities
As provided by law.
Retention of Reporting Documentation
Under Article 14 of Legislative Decree 24/2023, reports and related documentation are retained for the time necessary to process the report and in any case no longer than five years from the date of final outcome notification, in compliance with confidentiality obligations under Article 12 of the Decree and the principles of Article 5(1)(e) of Regulation (EU) 2016/679 and Article 3(1)(e) of Legislative Decree No. 51/2018.
Compliance with the Prohibition of Retaliatory Acts
In accordance with Article 17 of Legislative Decree 24/2023, Atis S.r.l. will observe the prohibition of any retaliatory acts against whistleblowers.
Atis S.r.l. reserves the right, at its discretion, to change, modify, add, or remove any part of this notice at any time, also in light of possible regulatory changes. To facilitate verification of any changes, the notice will include the update date.
Data Controller
ATIS S.r.l. – Via della Rupe 26 – 38017 Mezzolombardo (TN) IT
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