"Whistleblower" is anyone who becomes aware of a wrongdoing or irregularity in the workplace, while performing his or her duties, and decides to report it to a person or authority that can effectively act on it. While risking acts of retaliation because of the whistleblowing, the whistleblower is recognized as being in the public interest, giving knowledge of problems or dangers to his or her institution or community.

"Whistleblowing" is the activity of regulating procedures designed to make such reports easier to make and, at the same time, to ensure confidentiality and protection against retaliation for whistleblowers .

It is for these reasons that the new legislation (Legislative Decree No. 24/2023 implementing European Directive No. 1937/2019) provides (from Articles 16 to 22 inclusive) protective measures for the benefit of the reporting person in case of retaliation.

1. a) to objections, claims or requests related to a personal interest of the reporting person or the person who has filed a whistleblowing to the judicial or accounting authority that pertain exclusively to his or her individual employment relationships, or inherent in his or her employment relationships with hierarchically subordinate figures;
2. b) to reports of violations where already mandatorily regulated by the acts of the European Union or national acts indicated in Part II of the Annex to the Decree or national acts that constitute implementation of the acts of the European Union indicated in Part II of the Annex to Directive (EU) 2019/1937, although not indicated in Part II of the Annex to this Decree;
3. (c) to reports of national security breaches, as well as procurement related to defense or national security aspects, unless such aspects are covered by relevant secondary legislation of the European Union.

• LEGISLATIVE DECREE March 10, 2023, no. 24(link Normattiva website)
• Directive (EU) 2019/1937 (link European Parliament website)
• Privacy Policy (link to PDF document)
• Form for any reports in paper format (link to PDF document)

1. 1. INTERNAL: Reporting verbally or by ordinary mail to the Chairman of the Supervisory Board of KTC Srl (email: );
   2. INTERNAL: Sending ordinary mail, to the attention of the Chairman of the Supervisory Board of KTC Srl, at the address of KTC srl (Via Palazzon, 70, 36051 Creazzo VI )or by appointment with the Chairman of the SB, having the telephone number of the Chairman provided by the switchboard of KTC srl

1. 1. EXTERNAL: ANAC (ANAC website) National Anticorruption Authority - c/o Palazzo Sciarra, Via Minghetti, 10 00187 Rome PEC:  Contact Center 39 / 06 62289571;
   2. EXTERNAL: public disclosure through the press, electronic media or means of dissemination capable of reaching a large number of people;
   3. EXTERNAL: judicial authority with territorial jurisdiction.

The Chairman of the Supervisory Board undertakes to take, all arrangements to ensure that the identity of the reporter is not disclosed. The identity of the whistleblower is protected in any context subsequent to the report and cannot be revealed except in cases expressly provided for by legal regulations.

It will then be the responsibility of the Chairman of the Supervisory Board, once the report has been received, to give feedback to the reporter about whether the report has been taken care of. It will then be the responsibility of the Chairman, of the Body to acquire further information, from the offices concerned. Once the presence of all the elements useful to ascertain the facts has been established, the 'investigation will proceed. Reports by a person who reveals his or her identity and confidential reports (identity known only to the person receiving the report) are allowed. Therefore, it is requested to specify what level of confidentiality is intended.

Reports may be more effective than anonymous reports, as they still allow in-depth investigation through interlocution with the reporter, which may still take place, even by computer or analog (paper) means, even with an anonymous interlocutor.

The personal criminal and disciplinary liability of the whistleblower in the hypothesis of slanderous or defamatory reporting as well as civil liability under the Criminal Code and Article 2043 of the Civil Code remains unaffected. Any form of abuse of this procedure, such as manifestly opportunistic reports and/or those made for the sole purpose of harming the whistleblower or other persons, and any other hypothesis of improper use or intentional instrumentalization of the institution that is the subject of this procedure, are also a source of liability in disciplinary and other competent venues.

1) at the outcome of the investigations conducted, if the report is deemed unfounded, it shall proceed with its filing, drawing up a reasoned report;
2) at the outcome of the investigations conducted, if the report is considered well-founded, The Supervisory Board, transmits the investigative findings to the relevant corporate bodies (and in particular to the Board of Directors or the Board of Statutory Auditors if the offence concerns members of the Board of Directors). It ensures in any case that the documentation transmitted does not contain explicit or implicit references to the identity of the reporter