We have adopted a Procedure for handing reports, which defines a process of information flows for the receipt, analysis and determination of actions to be taken regarding presumed irregularities, ensuring the anonymity of the whistleblowers.
The Whistleblowing Procedure is in compliance with the provisions of the Model 231. It is a regulatory tool pursuant to our Anti-corruption Procedure and is an integral part of the corporate reporting internal control system.
The Whistleblowing Procedure applies to Italgas and its subsidiaries. In order to make it easier to receive the reports, we have set up specific communication channels indicated in the Procedure, 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 Head 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.
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 both for protecting the integrity of the persons mentioned in the notifications and the anonymity of those doing the reporting, so that they are not subjected to any form of retaliation.
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