The regulations governing “whistleblowing”, introduced into the legal system to combat potential corruption in the workplace, provides specific protection for whistleblowers who wish to report a violation, so that they may act without fear of suffering adverse consequences, is contained in Legislative Decree No. 24 of March 10, 2023, which implements EU Directive 2019/1937.

A “whistleblower” is defined as a person who witnesses a violation or irregularity in the workplace and decides to report it. The definition of “whistleblower” includes employees with fixed-term or permanent contracts, temporary agency workers, apprentices, interns, directors, collaborators, independent professionals, consultants, and employees of companies that supply goods or services.

The Inner Channel

Anyone who wishes to report unlawful conduct of which they have become aware in the course of their work at Eltek Srl may do so in one of the following two ways:

– in writing, by regular mail, using the form available for download in this section, in accordance with the instructions provided in the form itself and in the procedure, which is also available in this section;

– In-person meeting with the manager, by appointment only, in accordance with the procedures outlined in the form and guidelines available in this section.

The report must pertain exclusively to unlawful conduct and may not, therefore, be used by the reporter to submit personal grievances related to employment regulations.

By using the internal channel, the individual submits a report while intending to keep their identity confidential and to benefit from the protections provided in the event of any retaliation

The External Reporting Channel and Public Disclosure

The internal management channel should be used as a matter of priority.

Whistleblowers can use the external channel managed by ANAC by visiting the website https://www.anticorruzione.it/-/whistleblowing , exclusively in the following cases:

• the Company has not established an internal reporting channel, or the channel does not comply with Legislative Decree 24/2023;
  • A report has already been filed through the internal channel, but no action was taken;
  • The whistleblower has a well-founded fear that, if he or she were to use the internal reporting channel, the matter would not be effectively addressed or he or she might be subject to retaliation;
• The whistleblower has reasonable grounds to believe that the violation may pose an imminent or clear danger to the public interest.

Whistleblowers may also make a public disclosure (through the press and other media, such as social media) if any of the following conditions are met:

• the whistleblower has previously filed an internal and external report, or has directly filed an external report, and has not received a response within the established timeframes regarding the measures planned or taken to address the reports;
• the whistleblower has reasonable grounds to believe that the violation may pose an imminent or obvious threat to the public interest;
• The whistleblower has reasonable grounds to believe that reporting the matter externally could entail a risk of retaliation or might not be effectively addressed due to the specific circumstances of the particular case, such as situations where evidence may be concealed or destroyed, or where there is a well-founded fear that the recipient of the report may be colluding with the perpetrator of the violation or involved in the violation itself.

This does not preclude the possibility of filing a complaint with the competent national judicial and accounting authorities.