d’AMICO has always been particularly attentive to preventing risks that could compromise the responsible and sustainable management of its functions.
Therefore, d’AMICO, in line with the provisions of Italian Law no. 179 of 30 November 2017 laying down “Provisions for the protection of whistleblowers of crimes or irregularities of which they have become aware as part of a public or private employment relationship” and in line with the Corporate Governance Code of listed companies and international best practices, has adopted a dedicated “whistleblowing” channel to manage reports originating even from abroad.
This website can be used to report any irregularities and/or unlawful behaviours, acts or omissions that constitute violations, even suspected, of the principles ratified in the Group Code of Ethics, the Organisation, Management and Control Models pursuant to Italian Legislative Decree 231/01 of the Group d'Amico companies that have adopted them (d’Amico Società di Navigazione S.p.A., d’Amico Shipping Italia S.p.A. e d’Amico International Shipping S.A.), the Anti-Corruption Policy, as well as cases of bullying and/or sexual harassment and, in general, violations of company policies and rules that may constitute fraud or damage, even potential, towards colleagues, shareholders and stakeholders, or unlawful acts detrimental to the interests and reputation of the company.
d’AMICO has created this website to guarantee the confidentiality of the whistleblower's identity in managing the report.
The whistleblower's identity may be revealed - usually - only with the consent of the whistleblower himself/herself, except where this is necessary to guarantee the accused's right of defence in accordance with applicable law.
The confidentiality obligations, however, may not be imposed when the requested information is necessary for investigations or proceedings initiated by the judicial authority as a result of the whistleblower’s report.
INFORMATION IN ACCORDANCE WITH ART. 13 OF REGULATION (EU) 2016/679 ON THE PROCESSING OF PERSONAL DATA OF PERSONS REPORTING OFFENCES
Type of data processed and processing purposes
The data provided by the whistleblower in order to represent the alleged unlawful behaviours of which he/she has become aware based upon his/her service relationship with the d’Amico Group companies, committed by persons who, in various capacities, interact with those d’Amico Group companies, are processed, even from the technical profile, with the aim of carrying out the necessary preliminary activities to verify that the reported facts are well-founded, implementing any proceedings (even before the judicial authority) and adopting the consequent measures.
Legal basis of processing
The legal basis of processing is the legitimate interest of the Controller, the d’Amico group companies, in acquiring relevant information on any offences committed and incidents relating to different profiles of the organisation reported in the interest of the d'Amico Group companies.
The personal data acquired in the reporting procedure will be processed by personnel in charge of managing the report itself and through the use of manual, IT and electronic tools with logics strictly related to the processing purposes and, in any case, so as to guarantee the security and confidentiality of the data.
Those data will be stored for a maximum period of 10 years from the closure of the report.
Categories of personal data recipients
The data collected following the report may be sent, if appropriate, to third parties, such as the Judicial Authority, law enforcement authorities and other Regulatory Authorities. The personal data collected are also processed by employees of the Company, who act on the basis of specific instructions provided in relation to the processing purposes and methods.
Rights of the data subjects
The right of access to personal data by the data subject and the other rights envisaged by the personal data protection rules, with the limitations, regarding the whistleblower's confidentiality, relating to the indication to the accused of the origin of the data, may be exercised by contacting:
- the Data Protection Officer of the d’Amico Group, based in Corso d’Italia 35/B, 00198 – Rome – +39 06 845 611 fax +39 06 98968092 eMail: firstname.lastname@example.org.
Right to lodge a complaint with the Authority
Data subjects who believe that their personal data being processed through this website is occurring in violation of the provisions of the Regulation, may lodge a complaint, as envisaged by Art. 77 of the Regulation itself, or take action in the appropriate legal venues.
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