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Whistleblowing and Internal Reporting Channel<br />

Whistleblowing and Internal Reporting Channel

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Whistleblowing and Internal Reporting Channel

Studio Legale Associato in associazione con Clifford Chance, Milan and Rome

Studio Legale Associato in associazione con Clifford Chance (the "Law Firm") promotes a working culture in which everyone feels comfortable to speak out without fear of retaliation, in particular when reporting potential breaches within the terms of Italian Legislative Decree 24/2003 (Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, on the protection of persons who report breaches of Union law and establishing provisions on the protection of persons who report breaches of national laws) (the "WB Decree"), which governs the protection of persons who report breaches or irregularities of public and private entities, thereby facilitating the detection of wrongdoing. This is one of the guiding principles of our Code of Conduct. Pursuant to the WB Decree, the choice of reporting channel is no longer left to the discretion of the whistleblower, since priority is given to the use of the Law Firm's so-called "Internal Reporting Channel" by means of the following methods:

  • In writing: using our form, to be sent in a sealed envelope marked "private and confidential" by post, or by delivering that sealed envelope in person to, the following address: 

    Studio Legale Associato in associazione con Clifford Chance
    Internal Reporting Channel
    Via Broletto 16
    20121 Milan
    Italy
    For the attention of the Compliance Officer
     

FORM – INTERNAL REPORTING CHANNEL
 

  • Verbally: by calling +39 02 80634 559 in order to leave the relevant report with the reporting channel operator or the Law Firm's voice messaging service; or
  • In person: by scheduling a meeting in-person, upon formal request of the whistleblower, by using one of the above-mentioned means of communication. The meeting in-person will take place within a reasonable term of not less than 7 (seven) days from the date of receipt of the request.

Please consult the Law Firm's regulations and extended policy concerning the handling and operation of the Internal Reporting Channel, the processing of personal data and other external reporting channels available on the following link:

OPERATION OF THE INTERNAL REPORTING CHANNEL – STUDIO LEGALE ASSOCIATO IN ASSOCIAZIONE CON CLIFFORD CHANCE – MILAN AND ROME OFFICES
 

NOTE: REPORTS ON EMPLOYMENT RELATIONS

Reports may not relate to complaints or requests linked to a personal interest of the reporting person and relating to individual employment relationships (e.g., labour disputes, discrimination, interpersonal conflicts), for which the "Human Resources" department is responsible. If received through the Internal Reporting Channel, such requests, if there is no harm to the public interest or integrity of the Law Firm, will be directed to the Human Resources department in accordance with the Law Firm's policies.

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