Cogne Acciai Speciali S.p.A. is committed to carrying out its activities according to the highest standards of integrity, legality, transparency, fairness, honesty and responsibility and expects all those who operate in its interests to act in accordance with the aforementioned ethical standards and also protect the integrity of the Company and its reputation.
The entire staff of Cogne Acciai Speciali - at every level of the organisation - is therefore required to promptly communicate circumstantiated reports of unlawful conduct or violations of the Organisational Model, pursuant to Legislative Decree 231/2001 and based on precise and concordant factual events.
The aforementioned reports shall therefore relate to:
any anomaly, atypicality, exception, violation or suspected violation regarding work activities with respect to the rules of conduct in the Code of Ethics and the Organisational Model;
compliance to national laws related to the company activity and the working environment of Cogne, regarding principles of conduct and methods of execution regulated by the protocols and corporate procedures relevant to Decree 231/2001.
Via this portal, disclosure and or grievance reports may be submitted whether they relate to violation of Legislative Decree 231/2001, or to other cases not covered by the above-mentioned regulations.
This system guarantees the confidentiality of the content of the report and allows reports to be submitted ANONYMOUSLY or NON-ANONYMOUSLY.
The reports are sent to a third party body identified in the Ethics Committee - whose action is governed by specific Regulations - which carries out investigation activities and, on the basis of the results, may file or - in the case of ascertained violations - proceed with the provisions of the reference legislation. In the case of a report pursuant to 231/2001 sent to the Ethics Committee, it will be forwarded to the SB (Supervisory Board), which retains exclusive competence. In the case of a report not relating to 231/2001, the Supervisory Board will forward it to the Ethics Committee.
In the case of ANONYMOUS reports, personal data of the reporter are kept entirely CONFIDENTIAL and therefore NOT forwarded to the Ethics Committee, which receives only - in addition to the content of the report - a unique identification code, which is indispensable for tracing the sender, should this be necessary for actioning policy and procedure as envisaged by Regulations.
In the case of a NON-ANONYMOUS report, the Ethics Committee receives the reporter's personal data.
The Ethics Committee is bound to secrecy with regard to the news and information acquired in the performance of its duties and to their processing in compliance with current privacy legislation.