A report can be submitted through the web channel, via the MYGOVERNANCE platform, designed to guarantee, through IT tools, the utmost confidentiality of the whistleblower's identity in compliance with Legislative Decree 24/2023.
The following parties may submit a report:
- all stakeholders of Aircare Srl Società Benefit and Harpa Italia Srl, including employees, collaborators, suppliers, customers, business partners, local communities, and other parties who have direct or indirect relationships with the company.
- all employees of Aircare Srl Società Benefit and Harpa Italia Srl, regardless of their contractual status;
- self-employed workers, collaborators, freelancers, consultants, volunteers, and interns of Aircare Srl Società Benefit and Harpa Italia Srl;
- shareholders and individuals who hold administration, management, supervisory control, or representation roles within Aircare Srl Società Benefit and Harpa Italia Srl.
The report must be detailed enough to allow verification of the reported facts and must concern:
- illegal conduct relevant under current legislation, including any violations of codes of ethics, company regulations, or internal procedures adopted by Aircare Srl Società Benefit;
- violations of European or national regulations concerning transparency, integrity, public health, environmental protection, product safety, consumer protection, or any other area relevant to the public interest;
- conduct or omissions that may harm public economic or financial interests, whether at national or European level;
- actions or omissions that alter or compromise the proper functioning of the market, including anti-competitive behavior, undue economic advantages, or tax irregularities;
- any conduct that may compromise the purposes and principles of European or national regulations in areas of general interest;
- any other possible administrative, accounting, civil, or criminal offense of any nature, other than those listed above.
The following will not be taken into consideration:
- disputes, claims, or requests of a personal nature made by the whistleblower relating exclusively to their own individual employment relationships, including with hierarchically superior figures;
- violations already governed by specific regulations for which other reporting obligations are provided through dedicated channels;
-matters concerning national security and defense.
Once a report is received, the process will follow these steps:
- Initial assessment: preliminary analysis to determine the validity and relevance of the report.
- In-depth investigation: if necessary, a detailed investigation is initiated to verify the reported facts.
- Communication with the whistleblower: if the report is accepted, the whistleblower will receive regular updates on the handling of the complaint and will be informed when a resolution is reached. If the report is not accepted, a clear explanation of the reason for rejection will be provided.
- Resolution: adoption of appropriate corrective measures based on the outcome of the investigation.
The whistleblower may not be subjected to discrimination or retaliation for having made a report, provided they acted in good faith and had reasonable grounds to believe that the information reported was true and relevant.
Conversely, whistleblower protection ceases to apply once criminal liability has been established, even by a first-instance judgment, for defamation or slander, or for other offenses committed in connection with the filing of the report, or once the whistleblower's civil liability has been established in cases of willful misconduct or gross negligence. Aircare Srl Società Benefit reserves the right to act to protect its own interests, including in defense of injured parties.
In order to ensure maximum protection of confidentiality, when submitting a report the whistleblower must:
- use only personal devices;
- register on the online platform and submit reports using a personal email address.
Aircare Srl Società Benefit is clearly and formally committed to protecting anyone who submits a report in good faith through the channels made available by the company from any form of retaliation. This commitment extends to all stakeholders, including employees, collaborators, suppliers, customers, and partners.
Aircare Srl Società Benefit firmly condemns any act of retaliation and has adopted organizational and procedural measures to prevent and counter any retaliatory behavior.
In particular:
- It is expressly prohibited to carry out acts of discrimination, dismissal, suspension, demotion, transfer, or any other organizational measure that may have direct or indirect negative effects on the whistleblower as a result of the report submitted.
- Consequences in the event of retaliation by anyone within the organization will be subject to disciplinary action, up to and including dismissal in the most serious cases, in compliance with current regulations and applicable collective agreements.
Aircare has adopted specific protective mechanisms to ensure whistleblower protection, including:
- the use of a secure digital platform managed by an independent third-party provider, which ensures anonymity and traceability of communications;
- the separation of report management channels from hierarchical channels;
- the ability for the whistleblower to monitor the progress of their report;
- the confidentiality of the whistleblower's identity, unless otherwise indicated or required by law.
Aircare also reserves the right to take legal action against anyone who engages in retaliatory acts, including in defense of any parties who may have been harmed. Go to the MyGovernance website
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