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