Whistleblowing - Reports of violations

According to D.Lgs. n.24 of 10 March 2023, IBSA Farmaceutici encourages reporting anyone who, in the context of work, has become aware of hypotheses of violations of the Organization, Management and Control Model of IBSA Farmaceutici Italia S.r.l. (Model 231) , the Code of Ethics, the Anti-Corruption Guidelines and Policy ISO 37001:2016 of IBSA Farmaceutici, or other hypotheses of violation of the law that could put IBSA Farmaceutici's business or reputation at risk or that could cause damage to third parties.

Reporting requirements

Each report must contain the following elements:

  • the personal details of the reporter, in the event that the person making the report does not opt for anonymous mode;
  • a clear and complete description of the facts being reported; 
  • if known, the circumstances of time and place in which they were committed;
  • if known, personal details or other elements (such as the qualification and the service in which he carries out the activity) that allow to identify the subject (s) who has/have carried out the reported facts;
  • the indication of any other subjects who can report on the facts subject to the report;
  • an indication of any documents which may confirm the validity of those facts;
  • any other information that can provide useful feedback on the existence of the facts reported.

It should be noted that:

  • reports based on mere suspicion or rumors, unreliable, will not be taken into account;
  • anonymous reports fall under the subject of this document only if they meet the above requirements;
  • reports concerning disputes, claims or requests related to a personal interest of the reporter that relate exclusively to their individual employment relationships, including, but not limited to, labor disputes or friction between colleagues, are not allowed.

Internal reporting channels

Reports can be submitted using one of the following internal reporting channels:

  • Mail: IBSA Farmaceutici Italia Srl – Via Martiri di Cefalonia, 2 – 26900 Lodi (LO). To the attention of the Compliance Office marked "Confidential"
  • Web https://ibsawhistleblowing.whistlelink.com – Written or oral reports

Oral reporting is also permitted, at the request of the Whistleblower, through a direct meeting with the Head of Compliance Function of IBSA Group to be requested using the channels indicated above.

Each report will be evaluated to determine its suitability for management.
Reports will always be managed guaranteeing the confidentiality of the whistleblower and the lack of retaliation against him.
In the case of anonymous reports, the whistleblower may be asked to reveal his identity, always with the guarantee of confidentiality and the protections provided for by the UE Directive 2019/1937 on Whistleblowing.

External reporting channels

In some cases, you can send the report to ANAC (Autorità Nazionale Anticorruzione - National Anti-Corruption Authority).
It is possible to do so ONLY IF one of the following conditions is met, of which the whistleblower must be able to have evidence:

  • following a report, made through the use of the Company's internal channel, the same was not managed;
  • the whistleblower has reasonable grounds to believe that, if he made an internal report, it would not be effectively followed up or that the report could determine the risk of retaliation; 
  • the reporter has reasonable grounds to believe that the breach may constitute an imminent or manifest danger to the public interest.

Finally, public disclosure through the press or electronic means or means of mass communication capable of reaching a large number of people can be used ONLY if one of the following conditions is met, of which the whistleblower must be able to have evidence:

  • the whistleblower has already made an internal and external report, or has directly made an external report and has not been answered within the deadlines provided for on the measures envisaged or adopted to follow up on the reports; 
  • has reasonable grounds for believing that the breach may constitute an imminent or manifest danger to the public interest; 
  • has reasonable grounds to believe that external reporting may involve a risk of retaliation or may not be effectively followed up due to the specific circumstances of the case, such as those where evidence may be concealed or destroyed, or where there is a well-founded concern that the whistleblower may be colluding with or involved in the breach.

Download here” the Whistleblowing Policy of IBSA Farmaceutici