Whistleblowing Policy
1. Introduction
Buonocore Gioielli S.r.l. adopts this Policy in implementation of Legislative Decree No. 24 of March 10, 2023, which transposes EU Directive 2019/1937 on the protection of persons who report breaches of Union and national law.
This Policy governs the management of internal reports of unlawful acts and irregularities, ensuring whistleblower protection, confidentiality, and regulatory compliance.
2. Scope of application
This Policy applies to all individuals who work with or for Buonocore Gioielli S.r.l. in any capacity, including:
- Employees
- Collaborators and consultants
- Suppliers and business partners
- Interns, volunteers, former employees, and job applicants
3. Subject of the report
In good faith, the following may be reported: unlawful conduct, breaches of national or EU regulations, or behavior contrary to the company’s Code of Ethics, including:
- Administrative, accounting, civil, or criminal offenses
- Conduct endangering health, safety, the environment, or consumer rights
- Abuse of office, corruption, fraud, or other crimes
- Violations of internal company policies
Free-form reporting via e-mail
It is also possible to submit a free-form report, providing detailed information, to the same e-mail address.
Anonymous reporting
Anonymous reporting is permitted. However, it is recommended to include as much detail as possible to facilitate verification.
To be considered valid, a report must include:
- A clear and detailed description of the facts
- Information on times, places, persons involved, and methods
- Any supporting documents or evidence
Reports that are unfounded or made in bad faith may result in disciplinary measures or legal action.
4. Report management
Reports are reviewed by a dedicated internal team, in an impartial, confidential manner, and in compliance with data protection laws.
The process includes:
- Receipt and registration of the report
- Preliminary verification
- Internal investigation
- Adoption of corrective or disciplinary measures, if needed
5. Whistleblower protection
Buonocore Gioielli S.r.l. guarantees:
- Confidentiality of the whistleblower’s and involved parties’ identities
- Protection against any form of retaliation, penalization, or discrimination
- Access to appropriate remedies in the event of whistleblower rights violations
6. Archiving and retention
All reports and related documentation are stored in secure, confidential archives for five years, in accordance with Regulation (EU) 2016/679 (GDPR).
7. Contacts
For further information or clarifications: segnalazioni@buonocoregioielli.com