Rest of the World: Whistleblowing Policy & Report

The purpose of this procedure is to regulate the process by which personnel of Manuli Ryco S.p.A. group (“MR group”) can notify, anonymously or not, the Corporate Internal Audit Department or the Corporate Legal Department potential or suspected violations of: i) legal or regulatory requirement, ii) internal policy relating to accounting standards and disclosures, iii) internal accounting controls, iv) potential losses related to the internal or external audit of MR group’s financial statements.
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Who can make a report?
An employee of the MR group, who reasonably believes that another MR group employee or another person acting on behalf of the MR group, including an agent or representative, has violated an internal policy or procedure or regulatory requirement, may makes a whistleblowing report.
The whistleblower may put in place the report either by disclosing his or her identity or anonymously.
What can be reported?
Pursuant to Procedure COR IA04 “Whistleblowing Policy” the whistleblower may report potential or suspected violation of:

  • legal or regulatory requirement;
  • internal policy relating to accounting standards and disclosures;
  • internal accounting controls;
  • potential losses related to the internal or external audit of MR’s group’s financial statements.

Whistleblowing reports should be factual, rather than speculative or conclusory, and should contain as much specific details as possible to follow the proper assessment.

The whistleblowing report should be candid and clearly set out all the information the whistleblowers know about the alleged violations.

Reporting Channel

Whistleblowing reports can be sent to the Corporate Internal Audit Department and/or to the Corporate Legal Department at the following address:

The Corporate Internal Audit Department will immediately inform the Corporate Legal Department (in case not informed by the whistleblower) and, if deemed necessary, also to the group CEO of the whistleblowing report received.

Protection of the Whistleblower
MR guarantees full protection for whistleblowers ensuring the confidentiality of their identity and of the facts forming the subject of their report from the time when the report is received. It forbids all direct and indirect forms of retaliatory or discriminatory actions and behaviors towards the whistleblowers as a result of the report, including those which are attempted or threatened, as well as those directed against any employee assisting in the investigation.
Description of the process
After receiving a whistleblowing report, the Corporate Internal Audit Department and Corporate Legal Department will make a determination as to whether a reasonable basis exists for commencing an investigation on the conduct reported in the whistleblowing report.

If at the end of the initial determinations, it is deemed necessary to carry out an investigation of the reported conduct, all necessary measures will be taken to implement a thorough investigation of the allegations, including, if necessary, by using external consultants or the support of MR group management. The involvement of the local management of the location where the violation was reported will be evaluated on a case-by-case basis.

It may be decided not to initiate an investigation if the allegations in the whistleblowing report are not specified and factually supported.

Monetary Awards
If the investigation highlights misconduct to the detriment of MR group, the whistleblower (if non anonymous) will be rewarded with a compensation equal from one to two monthly net salary depending on the quality of the information and the significance of the violations. Such compensation will be paid within two months from conclusion of investigation by the company for which the whistleblower works.
Retention of Complaints and Documents
The Corporate Internal Audit Department and/or Corporate Legal Department will retain all documents and records regarding any whistleblowing report.