CARRARA S.P.A. has always been committed to preventing risks that could undermine the responsible and sustainable management of its business.
For this reason, CARRARA S.P.A. has implemented an Organization, Management, and Control Model pursuant to Legislative Decree no. 231/2001 ("Model 231"), which includes a Code of Ethics and a whistleblowing procedure.
CARRARA S.P.A. has also entrusted a Supervisory Body ("OdV")—an independent and autonomous entity—with the task of monitoring compliance with the provisions of Model 231, assessing its actual effectiveness, and evaluating the need for any updates.
In this context, Law no. 179/2017, titled "Provisions for the protection of those reporting crimes or irregularities discovered within the context of public or private employment," introduced the whistleblowing tool.
Through Law no. 2022/127, the Italian legislator authorized the Government to transpose Directive (EU) 2019/1937 on the protection of individuals in the public and private sectors who report violations of EU law, with the possibility of extending it to other acts/sectors at the discretion of member states. On March 10, 2023, the Council of Ministers approved Legislative Decree no. 24 to adapt the EU Directive.
This is a tool designed to protect the integrity of CARRARA S.P.A., allowing reports—also confidentially—to be submitted to the Supervisory Body concerning any behaviors observed in the course of one's duties within CARRARA S.P.A. that may constitute violations of Model 231, unlawful conduct relevant under Legislative Decree no. 231/2001, or violations of EU regulations across a wide range of areas explicitly listed in the annex to Directive (EU) 2019/1937 (including public procurement, financial services, product and transport safety, environment, food safety, public health, privacy, network security, and competition).
To this end, CARRARA S.P.A. has established a whistleblowing procedure that ensures two confidential reporting channels to the Supervisory Body for potential non-compliance with Model 231, ethical principles, applicable laws and regulations, or the other areas covered by the law.
The use of this procedure is limited to cases where the whistleblower, having obtained the information within the scope of their duties, acts in good faith, and the report is based on specific and consistent factual elements.
CARRARA S.P.A. encourages the reporting of irregularities in good faith but does not tolerate false or vexatious statements, mere suspicions or rumors, personal grievances, or claims.
In such cases, disciplinary actions will be taken against those who misuse the whistleblowing procedure.
CARRARA S.P.A. has implemented (i) a web-based IT platform; (ii) a dedicated voicemail system for reporting. Both channels ensure compliance with confidentiality regulations regarding the identity of the whistleblower, the reported party, any third parties/witnesses mentioned, and the facts outlined in the report.
Depending on the subject matter for which the whistleblowing report is to be submitted, the specific form must be completed, namely:
MODULO A (“Segnalazioni 231”)
per le violazioni del Modello 231, Codice Etico ovvero condotte illecite rilevanti ai sensi del d.lgs. n. 231/2001 MODULO B (“Altre segnalazioni”)
per le altre violazioni della normativa comunitaria in una gamma molto ampia di settori espressamente indicati nell’allegato alla direttiva (UE) 2019/1937 (tra questi: appalti pubblici, servizi finanziari, sicurezza dei prodotti e dei trasporti, ambiente, alimenti, salute pubblica, privacy, sicurezza della rete, concorrenza).