Whistleblowing

What is Whistleblowing?

Whistleblowing is the internal reporting system that allows employees, collaborators, suppliers and anyone who becomes aware of regulatory violations in the context of FinDynamic S.r.l.'s activities to make reports in a confidential and protected manner.

FinDynamic is committed to guaranteeing the confidentiality of the whistleblower's identity and protecting good-faith reporters from any form of retaliation.

What can be reported?

Violations of national or European Union regulatory provisions may be reported, including:

• Violations of rules on financial services, products and markets
• Administrative, accounting, civil or criminal offences
• Behaviour contrary to the principles of the company's Code of Ethics
• Violations regarding personal data protection (GDPR)
• Accounting or balance sheet irregularities
• Violations of anti-money laundering and anti-corruption rules

Who can report?

The following can make reports:

• Employees and collaborators of FinDynamic S.r.l.
• Self-employed workers and freelancers collaborating with the company
• Suppliers, commercial partners and their employees
• Trainees, interns and volunteers
• Former employees who become aware of violations during the employment relationship

How to submit a report

Reports can be submitted through the following channels:

Reports can also be made anonymously. FinDynamic will treat every report with the utmost confidentiality.

Whistleblower protection

FinDynamic guarantees full protection to good-faith whistleblowers. In particular:

• The whistleblower's identity is protected and cannot be disclosed without their consent
• Retaliation, discrimination or penalisation of any kind is prohibited
• The confidentiality of information contained in the report is guaranteed
• Bad-faith whistleblowers or those making false reports may be subject to liability

Report management

Reports received are managed by the designated officer with the following timescales:

• Within 7 days: Acknowledgement of receipt of the report to the whistleblower (if not anonymous)
• Within 3 months: Feedback to the whistleblower on the progress of the report
• Information contained in reports is retained for the time necessary for processing and in any case no longer than 5 years