Whistleblowing

Whistleblowing Platform

SPEA believes that operating correctly and ethically is not only a duty but also an opportunity for development in today’s industrial and social world. For this reason, it has introduced a Code of Ethics and Conduct that is binding for all individuals working within it, suppliers, and, in general, all Company stakeholders.

SPEA encourages all its Stakeholders to report any behavior that violates the Code of Ethical Conduct.

To this end, SPEA has established a channel to receive reports of violations of regulations or the Code of Ethical Conduct. This is intended to ensure fairness and transparency in the conduct of its business and activities and to protect the company’s position and image from conduct that could cause harm or prejudice to the company. It also ensures compliance with the regulatory provisions of Legislative Decree No. 24 of March 10, 2023, on whistleblowing, titled “Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council of October 23, 2019, on the protection of persons who report breaches of Union law and laying down provisions concerning the protection of persons who report violations of national laws.”  

This software tool has been developed for submitting reports in written form.  

The reporting person may also choose to submit the report anonymously; in any case, the confidentiality of the reporting person’s identity and the content of the report is guaranteed.

The report will be promptly handled by the Whistleblowing Committee.

After submitting the report, the reporting person will receive a personal reference number. Please make a careful note of this number, as it will be required to access the platform again and check for communications and/or updates provided. Indeed, to ensure the confidentiality of the reporting person, the Committee can only request further clarifications or provide responses through the portal.

It is recommended to periodically check for any updates to the report.

In compliance with the Whistleblowing Directive and its own Code of Ethical Conduct, SPEA prohibits any retaliation against any Stakeholder who has reported, in good faith, any non-compliant behavior, while simultaneously protecting the rights of the reported individuals.

If a report is found to have been made for the purpose of harming or otherwise causing prejudice to the reported person (report made in “bad faith”), it shall constitute liability for calumny or defamation, prosecutable under the law.

Information Notice on the Processing of Personal Data within the Scope of the Whistleblowing Procedure

Pursuant to Art. 13 of Regulation (EU) 2016/679, the company SPEA S.p.A., with registered office in Volpiano, Via Torino No. 16, as Data Controller, informs data subjects about the purposes and methods of processing of collected personal data, the scope of their communication and dissemination, as well as the nature of their provision.

1. Purposes of processing and nature of the main data processed

We process your personal data for the following purposes:

a) Purposes related to compliance with obligations deriving from Legislative Decree 231/2001 and Legislative Decree 24/2023 regarding reports of illicit acts.

The personal data processed generally fall into the category of personal identification data, contact details, and data related to organizational positions.

The data subject may also choose to use the reporting portal anonymously.

2. Data processing methods

We minimize the collection and processing of your personal data to what is strictly necessary for the purposes pursued, as previously identified. Data is processed and stored using suitable tools to ensure its security, integrity, and confidentiality through the adoption of adequate security measures as required by law.  

Data may be processed in both paper and electronic format.

Data is processed within the borders of the European Union.

3. Anonymous reports

Acknowledging the legitimacy of anonymous reports as well, the provision of your data is optional, and your refusal to do so will not have any consequence on the validity of the report or the actions of SPEA’s Whistleblowing Committee.

The reporting person remains, in any case, personally responsible for any defamatory content in their communications, and SPEA, through its Whistleblowing Committee, reserves the right not to consider reports made in evident “bad faith.”

SPEA also reminds you that the data provided must be relevant to the purpose of the report; therefore, the Whistleblowing Committee will be free not to follow up on reports concerning conduct or individuals unrelated to the obligations arising from compliance with SPEA’s Code of Ethical Conduct.

4. Communication or dissemination of processed data

The collected data will not be disclosed to third parties without the express consent of the data subject, except for any communications to authorized third parties – bound by confidentiality or, where applicable, appointed as data processors pursuant to Art. 28 of Regulation (EU) 2016/679 – where necessary for the purposes set out in this notice.  

Data may be communicated to competent authorities to comply with legal obligations.

Personal data cannot be transferred outside the European Economic Area.

5. Rights of the Data Subject

The data subject may exercise their rights as set out in Articles 15 to 22 of Regulation (EU) 2016/679 by contacting the Data Protection Officer (also “DPO”) appointed by the Data Controller directly, via email at privacy@spea.com or by ordinary mail addressed to the DPO c/o the Company’s headquarters at Via Torino No. 16, Volpiano (TO).

Specifically, under applicable law, the data subject has the right to:

a) request access to their personal data from the Data Controller;

b) request the Data Controller to rectify, supplement, or erase their personal data, transform it into an anonymous form, or restrict its processing;

c) object to the processing of their personal data;

d) request data portability;

e) lodge a complaint with a supervisory authority.

6. Changes and updates

This information notice may be subject to changes and additions, including as a result of updates to applicable legislation.
For any requests for information regarding the processing of your personal data, the exercise of your rights, or for reporting matters (including security vulnerabilities in processing, breaches of data processing principles, incidents), please refer to the following email address: privacy@spea.com