Notification procedure

We have adopted a Procedure for handling reports, also in anonymous format, which defines a process of information flows for the acceptance, examination and decision-making on action to be taken in relation to alleged irregularities.

The Notification Procedure covers the obligations envisaged in the Organisational and Control Model (231). It constitutes a regulatory tool pursuant to the Anticorruption Procedure and it is an integral part of the corporate information internal control system.

The Notification Procedure applies to Italgas and its subsidiaries. In order to facilitate the receipt of notifications, we have set up the specific communications channels indicated in the Procedure, the maintenance of which is ensured by the Internal Audit unit.

Each notification is analysed by the Notifications Committee, composed of the Director of Human Resources & Organization, the Director of Legal and Corporate Affairs and Compliance and the Internal Audit Manager, which ensures the necessary requirements of independence, confidentiality and competence. Once the analysis has been completed, the notifications received are classified according to issues relating to the internal control system, corporate information, administrative liability of the company, fraud, corrupt behaviour or other issues (breaches of the Code of Ethics, mobbing, thefts, security, etc.).

It is the responsibility of the Internal Audit department to promptly inform the senior management of the company concerned and to forward notifications to the company’s Supervisory Body for the relevant evaluations and actions.

Guarantee of anonymity

All Italgas organisational units/positions and the subsidiaries involved in receiving and dealing with notifications should guarantee the complete privacy and anonymity of the persons making the reports, using the criteria and communication methods suitable for protecting the integrity of the persons mentioned in the notifications, as well as the anonymity of those doing the reporting, so that they are not subjected to any form of retaliation.