STUDIO TRANSIT

Whistleblowing

A confidential channel for reporting breaches identified in a work-related or professional context connected with Studio Transit.

The reporting system

Studio Transit S.r.l. provides internal channels for receiving and handling reports of breaches in accordance with Procedure PR 01, which forms an integral part of its Organisation, Management and Control Model adopted pursuant to Italian Legislative Decree No. 231/2001. 231/2001.

The system safeguards confidentiality and promotes responsible use of the reporting channels. Reports must be relevant and sufficiently detailed. Reporting persons must have reasonable grounds to believe that the information is true at the time of reporting.

Reports may be submitted directly to the person responsible for handling reports, without first notifying a line manager or any other person.

Who can report

The channels are available to people who have obtained information in a work-related or professional context connected with Studio Transit, including:

Shareholders and members of the company’s administrative, management, control, supervisory or representative bodies, including the Supervisory Body.
Self-employed collaborators, professionals, consultants and employees, where applicable.
Employees, collaborators and other workers of suppliers, contractors, subcontractors and other entities operating on behalf of or in the interests of Studio Transit.
Trainees and volunteers, where applicable.
Job applicants and people at the pre-contractual stage, in relation to information obtained during recruitment or negotiations.
People whose relationship with Studio Transit has ended, in relation to information obtained during that relationship.

Protection applies subject to the conditions laid down by law.

What can be reported

Examples of matters that may be reported include:

Unlawful conduct relevant under Italian Legislative Decree No. 231/2001, and breaches of Studio Transit’s Model 231, Code of Ethics or adopted protocols.
Breaches of Italian or European Union law falling within the scope of Italian Legislative Decree No. 24/2023, where applicable to Studio Transit.
Fraudulent or corrupt conduct.
Significant irregularities in tendering procedures, contract awards, professional engagements, subcontracting, dealings with public authorities or reporting of expenditure and activities.
Falsification, alteration or concealment of technical, administrative, accounting, contractual or project documents.
Serious breaches of the controls established under Model 231 concerning traceability, segregation of duties, expenditure and financial flows.
Improper management of conflicts of interest, and other conduct that could expose Studio Transit to liability under Italian Legislative Decree No. 231/2001. 231/2001.

What falls outside the scope

The following matters do not normally fall within the scope of the whistleblowing channels:

Complaints, claims or requests relating to personal interests that concern only the reporting person’s individual employment, collaboration or professional relationship.
Complaints about service quality, invoices, payments, delays, or contractual or commercial disputes, unless the facts also constitute a reportable breach.
Clearly vague communications, reports lacking the minimum information needed for verification, or matters unrelated to Studio Transit’s activities.
Information already entirely in the public domain, without additional relevant details.

Submit a report

The main written reporting channel is the dedicated platform, which is also accessible to external users without company login credentials. It allows reports to be submitted anonymously and relevant supporting documents to be attached, limited to what is necessary.

Describe the facts and circumstances clearly and precisely, providing information that may assist with verification. Keep the code or access credentials issued by the platform: these allow you to maintain confidential communication with the person handling your report.

The external platform opens in a new tab.

Oral reporting

Reports may be made orally by calling the dedicated telephone number, which is accessible only to the person responsible for handling reports and, in the circumstances specified in the procedure, their designated alternate.

Dedicated telephone number: [INSERT DEDICATED TELEPHONE NUMBER]
Operating hours: [INSERT DAYS AND OPERATING HOURS]

Telephone conversations are not recorded. The person handling the report prepares a securely stored written account, which the reporting person may review, correct and confirm through arrangements that respect confidentiality and, where applicable, anonymity.

Direct meeting

At the reporting person’s request, the person responsible for handling reports will arrange a direct, confidential meeting within a reasonable time. A meeting may be requested through the platform or the oral reporting channel.

The meeting will be held in a manner that ensures confidentiality. It will be documented only with the reporting person’s consent, in minutes that they may review, correct and approve.

How reports are handled

The person responsible for handling reports is Studio Transit’s designated Model 231 contact person. In the event of a conflict of interest, personal involvement, absence or inability to act, responsibility is transferred to the alternate designated by Studio Transit.

The report is recorded in a confidential case file and undergoes a preliminary assessment to determine whether it falls within the scope of the reporting procedure and contains sufficient information to proceed. If necessary, the person handling the report may request clarification or additional information through the confidential channel.

Receipt of the report is acknowledged within seven days, where technically possible, unless doing so could compromise confidentiality or the reporting person has expressly requested not to receive an acknowledgement.

In accordance with Studio Transit’s procedure, feedback is provided within three months of submission of the report. It may concern the progress of the enquiries, the closure of the case, or measures taken or proposed, while respecting confidentiality and the rights of the individuals involved. Feedback does not necessarily mean that the enquiries have been completed.

Where it is not possible to contact the reporting person, for example because no contact details or means of confidential communication are available, neither an acknowledgement of receipt nor feedback can be provided.

Confidentiality and protection

The reporting person’s identity may not be disclosed without their express consent to anyone other than those authorised to receive or handle the report, except as provided by law. The identities of the people concerned and anyone mentioned in the report, as well as its content and attachments, are also protected.

Studio Transit prohibits retaliation, threats, discrimination, penalties and unfavourable treatment related to reports made in accordance with the conditions laid down by law. Within the limits and subject to the conditions laid down by law, protection also extends to facilitators who assist the reporting person, individuals in the same work-related context who have a stable emotional relationship or family ties with the reporting person, colleagues, and legal entities connected with the reporting person.

Reports are handled with respect for the rights of defence and the presumption that the person concerned is not responsible for the alleged breach. A report that proves to be unfounded does not automatically result in consequences for the reporting person. Any liability for intentional wrongdoing or gross negligence is determined by the competent authorities or bodies.

Personal data is processed for the purposes of handling reports and complying with legal obligations, in accordance with the dedicated privacy notice.

Anonymous reports

Studio Transit also accepts and handles anonymous reports, provided they contain sufficient detail to allow verification. The platform allows anonymous reporting persons to maintain confidential communication with the person handling their report through a code or equivalent system.

Where no contact details or means of communication are available, Studio Transit will still register the report, carry out a preliminary assessment and, where sufficient information is available, conduct the necessary further enquiries. In these circumstances, it may be impossible to contact the reporting person.