Whistleblowing

In line with international best practices and in full compliance with applicable regulations, Mundys S.p.A. has implemented a process for collecting and managing Reports. The current whistleblowing management system features the following:

• management of whistleblowing in each Group Company, through specific whistleblowing channels and accountability to the Whistleblowing Committee in the interests of timeliness and effective analysis, except for common safeguarding requirements of the Mundys Group and/or the holding company Mundys S.p.A.;
• the assignment, without prejudice to the collegiality of the Whistleblowing Committee, of a key role to the Internal Audit in managing process, from receipt of Reports to implementation of the preliminary investigation;
• provision of information flows with the other actors in the Internal Control and Risk Management System.

In order to ensure the effectiveness of the reporting process and provide total and indiscriminate access to all those who wish to make a Report, Mundys S.p.A. provides various channels, including:

• an IT platform, accessible to all whistleblowers (employees, third parties, etc.) on the Mundys website and on Mundys intranet, where a written or oral Report may be submitted;
• an email sent to: SEGNALAZIONI.MUNDYS@MUNDYS.COM
• ordinary mail sent to: Mundys S.p.A., Mundys Whistleblowing Committee, Piazza San Silvestro, 8 - 00187 Rome, Italy. 

Oral reports may also be directly made at a meeting with the Whistleblowing Committee or one or more of its members, if requested by the Whistleblower.

If possible, use of the first channel (IT platform) is preferable.

Whistleblowing is a tool for improving the Internal Control and Risk Management System as a whole and helps to spread a culture based on ethical behaviour, legality and transparency within the Group.

Although submission of anonymous Reports is a feasible alternative at Mundys, the Group recommends the submission of a non-anonymous Report, in order to speed up and facilitate investigations. Guarantees and protections whistleblowers are set out in a dedicated section, to which reference should be made.

Mundys guarantees the confidentiality of the existence and content of disclosures, as well as the identity of Whistleblowers (where disclosed) and Reported Parties. Moreover, Whistleblowers are protected in accordance with the law and there is a guaranteed follow-up for all disclosures.

For all those who wish to make a disclosure concerning other companies in the Group, specific channels are available on their respective websites.

Our Whistleblowing Committee

The members of Mundys Whistleblowing Committee, set up by the Chief Executive Officer, are as follows:

Mundys  Whistleblowing Committee performs the following main tasks: 

• it is responsible for the process of managing disclosures, assessing their adequacy and suggesting to the Board of Directors any improvements to the process, promoting the necessary information and training initiatives for the Group’s personnel;
• it supervises compliance with the Code of Ethics, examining reports of possible breaches and promoting the necessary checks and, where required, the consequent improvement actions, monitoring their effective implementation;
• it disseminates and verifies awareness of the Code of Ethics, promoting communication initiatives and activities aimed at increasing understanding of the Code;
• it proposes the issuance of guidelines and operating procedures or additions and amendments to existing ones, aimed at reducing the risk of breaches of the Code.

The Whistleblowing Committee is coordinated by the Internal Audit, Risk and Compliance Officer.

Mundys Whistleblowing Committee may also reserve the right to handle disclosures where it deems them to have a significant impact (e.g. reputational and/or economic/financial damage) for the Mundys Group (including the holding company) or on other Group companies. Moreover, it cannot be excluded that any such significant impact for the Mundys Group may also relate to disclosures received from subsidiaries.