A confidential channel for reporting unlawful conduct and breaches of the Code of Ethics or of the 231 Model. Those who report are protected by law and by company procedures.
The reporting channel
ISAB provides those who work with the company with a channel for reporting unlawful conduct and irregularities: a dedicated platform, managed by the Reports Officer, which safeguards the confidentiality of your identity and protects you from any retaliation. A report can be sent in writing, as a voice message or by asking for a meeting in person, and it may be anonymous. The frequently asked questions below explain who can report, what, and with which protections.
Anyone with an employment or professional relationship with ISAB: employees, collaborators, trainees and volunteers, workers of supplier and contractor companies, professionals and consultants, directors, control bodies, shareholders. Also those still in recruitment, those on probation and those who have already left the company, if the facts date from the period of the relationship.
I work for a contractor, not for ISAB. Does this apply to me too?
Yes. Same channels, same protections. You do not need to be an ISAB employee.
What can I report?
Criminal offences and civil, administrative or accounting wrongdoing. Breaches of the 231 Model and of the Code of Ethics. Facts that may damage the company’s assets or its reputation. Risks to health, safety and the environment. Breaches of the rules on public contracts, anti-money laundering, product safety, personal data and cybersecurity. It covers attempted conduct as well.
And what falls outside?
Personal matters of the employment relationship: grading, shifts, leave, friction with a colleague or with your line manager. Other company channels exist for those, and coming through here only slows the answer down.
How do I report?
Three ways. The isab.segnalazioni.net platform, which is the most direct channel. A recorded voice message, from the same platform, if you would rather speak. A meeting in person with the Reports Officer, requested through the platform and arranged within a reasonable time.
Do I have to register?
No. You can create an account with a username and password, or report without registering: in that case the system issues you a code and a password. Keep them, because without them you cannot get back into your report, and no one can recover them for you.
Can I stay anonymous?
Yes. If you choose anonymity, do not put anything in the text that identifies you, and check attachments before uploading them: names and history often remain in a file’s properties even when they do not appear in the document.
Who reads what I write?
The Reports Officer, who at ISAB is the Chair of the Supervisory Body, possibly with a dedicated working group. The content of the report arrives separately from your personal data, which stays encrypted in a separate archive: not even the platform provider can reach it.
Can anyone find out who I am?
Only in the cases provided for by law (criminal, tax or administrative investigations, inspections by control bodies) or in disciplinary proceedings where knowing your identity is essential to the defence of the person accused. In every case you receive written notice with the reasons, and every access to your identity is logged.
How long do I have to wait?
Acknowledgement of receipt is immediate. The first assessment closes within 15 days. A response on the report arrives within three months of the acknowledgement. In the meantime the Reports Officer may ask you for clarification.
How do I follow the case, and how do I add something I thought of later?
You go back into your area with your credentials or your code and write in the messages area. From there you can also see the status of the case. If you leave an e-mail address for notifications, use one that is not a work address.
I have already spoken to my line manager. Do I have to start again?
Anyone who receives a report outside the official channels must pass it to the Reports Officer within seven days and tell you they have done so. Protections, however, apply with certainty once the report enters the system: use the official channels if you can.
Do I risk consequences at work?
Retaliation is prohibited and penalised: dismissal, suspension, demotion, failure to promote, transfer, cuts to pay, exclusion from training, negative references, harassment, non-renewal of a fixed-term contract, termination of a supply relationship, withdrawal of licences. The prohibition also protects those who help you report, colleagues close to you and your relatives up to the fourth degree. Obstructing a report or disclosing your identity is penalised too.
And what if I actually suffer retaliation?
You report it to the Committee made up of the General Manager, the Chair of the Supervisory Body and the head of the Audit function, which examines the case and reports to the Board of Directors.
Can I go straight to ANAC?
Only in three cases: you have already reported internally and had no follow-up; you have well-founded reasons to believe you would not, or that you would expose yourself to retaliation; the breach is an imminent danger to the public interest. Outside these cases ANAC does not take the report on, and the protections do not apply.
And what if it turns out I was wrong?
If you reported in good faith, on the basis of facts you had reason to believe were true, there are no consequences for you: that is the point of the protections. Those who report what they know to be false, to harm someone or out of personal calculation, do answer for it.
How long do my data stay in the system?
Up to five years from notice of the final outcome. Once the case is closed, personal data are anonymised.