Reporting channels - whistleblowing system

The Company has approved the Organisation and Management Model pursuant to Legislative Decree 231/2001, which provides for a system that allows its workers to report any unlawful activities of which they become aware as part of their work (whistleblowing).
The term “crimes” refers to the commission (or attempted commission) of an offence that could give rise to liability pursuant to Legislative Decree 231/2001.
“Irregularity” refers to any conduct (carrying out or omitting) in the workplace in breach of the rules of the Code of Ethics and/or the Elba Assicurazioni S.p.A. Model. Breaches of the policies, procedures and regulations adopted by the Company are also considered “irregularities”.
Who reports
• persons with representation, administration or management functions at the Company or who carry out, including on a de facto basis, the management and control of the Company's activities;
• all employees, regardless of their contractual classification;
• persons that work with the Company and - more generally - undertake business relationships with it (e.g. customers, suppliers and consultants).
Recipient of the report
The Supervisory Board
Subject matter of the report
Reports must have regard to “substantiated” unlawful conduct or irregularities. Therefore, they must be complete with all information useful for reconstructing and verifying the reported act.
Methods of sending the report
organismo.vigilanza@revoinsurance.com, which is accessible only to members of the Supervisory Board
segnalazioni.odv@revoinsurance.com, which is accessible only to the Chairman of the Supervisory Board
• by priority post to the Company’s registered office, for the attention of the Supervisory Board
Protection of whistleblowers
In accordance with the provisions of the reference legislation, Elba protects the whistleblower from any form of retaliation or discrimination on grounds related, directly or indirectly, to the report. The disciplinary system provides for sanctions against persons who breach measures to protect the whistleblower, as well as persons who intentionally or negligently make reports that prove to be unfounded.