1. Purpose
This Policy governs the procedures for receiving, analysing and managing reports concerning behaviours, actions, omissions or company practices that are inconsistent with the principles of legality, fairness, integrity, gender equality, inclusion, protection of personal dignity and the prevention of any form of discrimination, harassment or retaliation.
The purpose of this Policy is to ensure a safe, confidential and accessible channel through which individuals can report critical or non-compliant situations, thereby contributing to the continuous improvement of the Company’s management system and, in particular, of the gender equality management system in accordance with UNI/PdR 125:2022.
2. Scope of Application
This Policy applies to reports submitted by:
- employees;
- collaborators;
- consultants;
- suppliers;
- partners;
- job applicants;
- former employees or former collaborators;
- other individuals who, in various capacities, have a relationship with the organisation.
Reports may concern facts, behaviours or situations occurring in the context of work activities, professional relationships or business relations.
3. Subject Matter of Reports
By way of example, the following may be subject to reporting:
- direct or indirect discrimination based on gender;
- harassment, sexual harassment, verbal, physical, psychological or digital abuse;
- offensive, disparaging or non-inclusive behaviour;
- unequal treatment in selection, recruitment, training, professional development, performance assessment or remuneration processes;
- obstacles to parenthood, maternity, paternity or work-life balance;
- retaliation or adverse treatment resulting from a report or a request for protection;
- violations of the Gender Equality Policy;
- behaviour contrary to the principles of fairness, transparency, integrity and respect for individuals;
- any unlawful acts or irregularities falling within the scope of the applicable whistleblowing legislation.
The following are not covered by this Policy: complaints, claims or requests of an exclusively personal nature concerning the individual employment relationship, unless they are connected to discrimination, harassment, retaliation, gender equality violations or other matters of general interest.
4. Reporting Channels
The organisation provides a confidential digital reporting channel accessible through the Company website, configured to allow reports to be submitted anonymously as well.
The channel allows the reporting person to describe the facts, attach any supporting documentation and, where technically available, maintain confidential communication with the person responsible for managing the report.
Reports may be submitted:
- in identified form, by providing one’s contact details;
- anonymously, without providing identifying information.
Anonymous reports will be considered where they are sufficiently detailed and supported by adequate information to allow an assessment of the facts.
Reports may also be submitted through the following channels:
- by email to the Gender Equality Steering Committee at paritadigenere@udanet.it;
- by ordinary mail to UD’ANET S.r.l., Piazza San Rocco sn, 66010 Torrevecchia Teatina (CH), Italy, writing “CONFIDENTIAL – GENDER EQUALITY REPORTING” or equivalent wording on the sealed envelope and addressing it to the attention of the Coordinator of the Gender Equality Steering Committee or the Human Resources Manager;
- through the online website reporting area at https://segnalazioni.udanet.it.
5. Persons Responsible for Managing Reports
Reports are managed by individuals specifically appointed and authorised by the organisation, who possess appropriate skills, autonomy and confidentiality requirements.
Depending on the Company’s organisational structure, responsibility for managing reports may be assigned to:
- the Gender Equality Steering Committee;
- the internal gender equality officer;
- an authorised HR function;
- an appointed external party;
- another formally appointed person.
The persons responsible for managing reports are required to handle each report with impartiality, discretion and confidentiality, avoiding any form of conflict of interest.
If a report directly concerns one of the persons responsible for managing reports, it shall be assigned to an alternative person, either internal or external, in order to ensure impartiality and independence.
6. Confidentiality and Protection of the Reporting Person
The organisation guarantees the utmost confidentiality regarding the identity of the reporting person, the person concerned, the persons mentioned in the report and the content of the report.
Where disclosed, the identity of the reporting person may not be disclosed to persons other than those authorised to manage the report, except where required by law or with the express consent of the person concerned. Any form of retaliation, discrimination, penalisation or adverse treatment against a person who submits a report in good faith is prohibited.
By way of example, retaliation may include:
- dismissal, suspension or equivalent measures;
- demotion or failure to promote;
- detrimental changes to duties or working hours;
- exclusion from training programmes or professional opportunities;
- discrimination, isolation, pressure or hostile behaviour;
- unjustified negative performance assessments;
- reputational or professional damage.
7. Minimum Content of a Report
To enable proper assessment, a report should contain, where possible:
- a clear description of the facts;
- the date or period in which the events occurred;
- the location or context;
- the persons involved;
- any witnesses or persons with relevant knowledge;
- any documents, messages, emails, screenshots or other supporting evidence;
- an indication of whether the situation is still ongoing;
- any consequences suffered or risks perceived.
Generic reports, reports lacking concrete information or manifestly unfounded reports may be archived following a reasoned assessment.
8. Report Management Procedure
Reports received are managed according to a structured process:
Receipt of the Report
The person responsible verifies receipt of the report and records its opening on a confidential basis.
Preliminary Assessment
It is verified whether the report falls within the scope of this Policy and whether it contains sufficient information to proceed.
Request for Additional Information, Where Necessary
Where necessary and technically possible, additional clarification or documentation may be requested from the reporting person.
Internal Investigation
The person responsible analyses the facts, collects any documentary evidence and, where appropriate, interviews the persons involved or informed of the facts, while respecting confidentiality.
Outcome of the Assessment
At the conclusion of the investigation, the report may be:
- archived if it is unfounded, insufficiently detailed or irrelevant;
- upheld, with the identification of corrective, preventive or disciplinary actions;
- forwarded to the competent functions if it concerns specific areas;
- managed in accordance with other applicable company procedures or legal obligations.
Monitoring of Corrective Actions
Where critical issues or non-conformities are identified, the organisation defines corrective actions and monitors their implementation.
9. Management Timescales
The Gender Equality Steering Committee initiates the report assessment procedure according to the following timescales:
- within 7 days: acknowledgement and preliminary assessment;
- within 15 days: commencement of the investigation, unless immediate action is required;
- within 30 days: completion of the investigation, where the complexity of the case allows;
- within 3 months: completion of the initial follow-up and verification of the measures adopted.
Where, due to the complexity of the case, the investigation cannot be completed within 30 days, the Coordinator of the Gender Equality Steering Committee shall document the reasons for the extension and establish a new timetable, while continuing to monitor the case until its conclusion.
10. Anonymous Reports
Anonymous reports are permitted and will be considered when they contain sufficiently detailed information to allow verification.
Anonymity must not prevent the responsible management of a report. For this reason, reporting persons are encouraged to provide a clear and comprehensive description of the facts and, where available, supporting documentation.
11. Protection of Personal Data
Reports are handled in compliance with applicable personal data protection legislation. The data collected are used exclusively for the receipt, management, verification and documentation of the report, as well as for the adoption of any corrective or protective measures.
Access to data is restricted to authorised persons only. Data that are irrelevant, excessive or unnecessary for the management of the report will not be used and, where possible, will be deleted or redacted. Information concerning the processing of personal data is made available through a specific privacy notice.
12. Retention of Documentation
Documentation relating to reports is retained for the time necessary to manage the report and, in any event, in compliance with the periods established by applicable legislation and Company procedures. Access to the documentation is restricted exclusively to authorised persons. Documentation is retained using appropriate measures to ensure the confidentiality, integrity and protection of the information.
13. Prohibition of Bad-Faith Reporting
This Policy protects reports submitted in good faith or based on a reasonable belief in the truthfulness of the reported facts. Manifestly false, malicious, defamatory reports, or reports submitted intentionally or through gross negligence for the sole purpose of harming other persons or the organisation, are not tolerated.
The protection of the reporting person remains in place where the report proves to be unfounded, provided that it was submitted in good faith and on the basis of reasonable grounds.
14. Link with the Gender Equality Management System
Reports concerning discrimination, harassment, unequal treatment, obstacles to parenthood, work-life balance issues or other matters relating to gender equality are considered relevant elements for monitoring the management system compliant with UNI/PdR 125:2022.
The outcomes of reports, in aggregated and anonymised form, may contribute to:
- identifying non-conformities;
- defining corrective actions;
- improving HR procedures;
- updating the Gender Equality Policy;
- periodically reviewing the management system;
- monitoring the organisational climate;
- preventing discriminatory or non-inclusive behaviour.
15. Communication and Dissemination
This Policy is made available to employees and other stakeholders through the Company channels deemed most appropriate, including the Company website.
The organisation promotes awareness of this Policy and of the reporting channel through information activities, internal communications and, where applicable, dedicated training sessions.