INTRODUCTION 
With Legislative Decree No. 24 of 10 March 2023, Directive (EU) 2019/1937 (the so-called “whistleblowing” directive) was transposed into the Italian legal system, setting out provisions for the protection of persons who report breaches of national regulations, with effect as from 15 July 2023. 
In accordance with the Directive and in compliance with current legislation, Zeta Farmaceutici S.p.A. has established special reporting channels in accordance with Legislative Decree 24/2023, through which recipients can report breaches of the law confidentially and without fear of retaliation.
 

WHO CAN MAKE A REPORT?
•    Company employees; 
•    self-employed workers who operate at the Company;
•    freelancers and consultants who provide services to the Company; 
•    paid or unpaid volunteers and trainees who carry out their activities at the Company; 
•    persons holding administrative, managerial, supervisory, oversight or representative roles in the Company, even where
such roles are exercised de facto.

HOW IS A REPORT MADE?  
Reports can be submitted in writing via this secure platform:

https://zetafarm.whistleblowing.it/#/

Alternatively, you can make a report by telephone via the dedicated helpline on this number: 366/6032171 – you can also leave a voicemail. The whistleblower can also request a face-to-face meeting with the manager of the reporting channel. The meeting will take place at a location that ensures the confidentiality of the whistleblower, within a reasonable timeframe and in any event no later than 20 days from the date of the request. 
Reports will be examined by the reports recipient, who is competent and authorised to be informed of the reported events for the purpose of investigating the matter and, where necessary, liaising with the whistleblower.

WHAT IS A REPORT AND WHAT CAN BE REPORTED 
A report is any communication, including reasonable suspicions, that concern actual or potential breaches that have occurred or are highly likely to occur, as well as attempts to conceal such breaches. It must relate to conduct by individuals at Zeta Farmaceutici S.p.A. that constitutes: a breach of laws and regulations or orders issued by authorities; a breach of national law (civil offences, administrative offences, criminal offences, accounting offences, breaches of organisation and management models) or; a breach of European Union legislation as set out in Annex 1 to Legislative Decree No. 24 of 10 March 2023, and all the national provisions implementing it. 

WHAT HAPPENS AFTER THE REPORT HAS BEEN SUBMITTED? 

• the whistleblower will receive a simple acknowledgement of receipt within seven days; 
• the whistleblower will receive a written response within three months of acknowledgement of receipt; 
• communication between the whistleblower and the reporting channel manager will take place, where applicable, via the encrypted platform, by telephone or in person. To this end, the whistleblower must retain the login details provided by the system.

FURTHER ORGANISATIONAL MEASURES 
In its handling of reports, Zeta Farmaceutici S.p.A. ensures that: 

• the whistleblower’s identity is kept confidential at every stage of the reporting process, so that they are not subject to any discrimination or pressure, whether direct or indirect; 
• the content of the report and the related documentation are kept confidential at every stage of the report management process; 
• the identity of the whistleblower cannot be disclosed (in the event of the launch of disciplinary proceedings where the whistleblower’s identity is essential for the defence of the accused party, the whistleblower may decide whether or not to consent to the disclosure of their identity so that their report can be used for the purposes of the proceedings); 
• the report is exempt from the right of access to data under Law 241/1990 (Articles 22 et seq.) and therefore may not be viewed or copied by any applicants.

ANALYSIS AND MANAGEMENT OF REPORTS  
The findings of the investigation into the reported cases are brought to the attention of special representatives appointed by Zeta Farmaceutici S.p.A.. We guarantee the utmost confidentiality regarding the matters and incidents reported, as well as the identity of the whistleblower, to ensure that they are not subjected to any form of retaliation. 
While it is preferred that you use the reporting channels made available by Zeta Farmaceutici S.p.A., note that in the cases strictly specified pursuant to Article 6 of Legislative Decree 24 of 10 March 2023, reports may also be made to the competent authority (ANAC). 
The information and personal data provided in the context of reports are processed for the purpose of managing and following up on the reports, as well as for investigating any conduct reported and for taking the necessary measures in accordance with applicable laws, including data protection legislation. For further information on the methods and purposes of processing the personal data included in reports and collected during the procedure, please refer to the privacy policies, available on this page, regarding the processing of data relating to whistleblowers, the accused parties, or other third parties involved.

PROHIBITION OF RETALIATION 
The provisions of Legislative Decree 24/2023 protect whistleblowers from retaliation carried out against them as a result of their report.  These protective measures do not apply in the case of false reports made with malice or gross negligence. In such cases, disciplinary action may be taken against the whistleblower. 
The whistleblower’s details will be retained for a maximum of 5 years from the conclusion of the reporting process.

PROCESSING OF PERSONAL DATA
The personal data and information provided within the scope of the reporting procedure is processed for the purpose of following up on reports, as well as for investigating any conduct reported and for taking the necessary measures in accordance with applicable laws, including data protection legislation. For further information on the methods and purposes of processing the personal data included in reports and collected during the procedure, please refer to the privacy policies, available on this page, regarding the processing of data relating to whistleblowers, the accused parties, or other third parties involved.

PRIVACY POLICIES 
Before proceeding, please read the privacy policies regarding the processing of data relating to the whistleblower, the accused party, and any third parties involved in the conduct reported, which are available at the following links:
 

Information regarding the reporting person’s privacy

Information regarding the privacy of persons concerned and third parties