Cogne Acciai Speciali S.p.A. operations and activities are carried out according to the highest standards of integrity, legality, transparency, fairness, honesty and responsibility and COGNE expects all those who operate in its interest to act in accordance with the aforementioned ethical standards, also to protect the image and reputation of the Company.
The staff of Cogne Acciai Speciali – at every level of the organization – is therefore required to promptly transmit detailed reports of any illegal conduct or violations of the Organizational Model relevant pursuant the Italian Legislative Decree 231/2001 based on precise and concordant facts.
The reports have to relate to any anomaly, atypicality, derogation, violation or suspected violation regarding:
- rules of conduct prescribed by the Code of Ethics and the Organizational Model 231/01 or compliance with national laws related to the company activity and the working environment of Cogne;
- principles of conduct and methods of execution governed by the relevant company protocols and procedures pursuant to Italian Legislative Decree 231/2001.
Through this portal, it is possible to submit reports, either related to violation of the Italian Legislative Decree 231/2001 or whether they refer to other cases not contemplated in the aforementioned legislation.
The system guarantees the confidentiality of the communication content and allows the reports to be send either ANONYMOUS or NON ANONYMOUS.
The reports are sent to COGNE Ethics Committee, a third part body whose actions are governed by a specific Regulation approved by the BoD of the Company – which is responsible for the investigation activities and, based on the results of the same, can – in the case of ascertained violations – proceed according to the legislation or file the report as unfounded. If the report refers to Italian Legislative Decree 231/01 the case is forwarded to the Supervisory Body (Organismo di Vigilanza), which retains exclusive competence.
In the event of an ANONYMOUS report, the personal data of the reporter are NOT transmitted to the Ethics Committee, which only receives – in addition to the content of the report – a unique identification code of the transaction, which is essential for tracing back to the sender, when this is necessary for the carrying out the operations necessary for the investigations. In the event of a NON-ANONYMOUS report, the Ethics Committee also receives all the personal data of the reporter.
The Ethics Committee Ethical is bound to secrecy with regard to all informations and datas acquired in the exercise of its functions and their treatment in relation to current legislation on Privacy.