Endurance’s Whistleblowing system, updated to 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, is made available to all stakeholders.
Whistleblowing
Reporting offences or irregularities Whistleblowing
Which are the reporting channels?
Endurance has made available for the reporting of unlawful conduct by employees, collaborators, directors, members of corporate bodies, and third parties (so-called whistleblowers) an IT platform, which can be accessed via the button below.
What can be reported?
Violations of national or European Union regulations that harm the public interest or the integrity of the public administration or the private entity, of which it has become aware in a public or private work context.
The reporting of offences must be perceived as an act of manifestation of civic sense that can facilitate the emergence of corrupt facts or in any case prejudicial to the integrity of the Company and to the collective interest. Through these channels it is therefore possible to report
- unlawful conduct relevant under Legislative Decree 231/2001 or violations of the Organisation, Management and Control Model (also referred to as ‘Model 231’);
- offences falling within the scope of European Union or national acts, acts or omissions affecting financial interests or affecting the internal market.
It is not possible to report through this channel matters of a personal nature, or relating to the discipline of the employment relationship or relations with one’s hierarchical superior or colleagues.
Any form of abuse, such as reports that are manifestly opportunistic and/or made with the sole aim of harming the whistleblower or other persons, and any other hypothesis of improper use or intentional exploitation of the institution that is the subject of this procedure, shall also give rise to liability in disciplinary and other competent offices.
Who will receive and investigate the report?
The report will be received by the Chairman of the Company’s Supervisory Body and by theGroupAudit and Compliance Office, both of which are members of the Supervisory Body, or, if it relates to a company without such a body, by the Group Audit and Compliance Office (so-called Reporting Officer). Once the fact is reported, an internal investigation is opened to ascertain the facts that are the subject of the report. It is therefore essential to make reports that are as circumstantial as possible and provide as many elements as possible to enable the competent bodies to carry out the necessary checks.
Following the report, the reporter/whistleblower may be contacted by the person who took charge of the report in the course of internal investigations, again through the platform, to request clarifications, in-depth information, documents or other matters, always respecting confidentiality and guaranteeing the effective management of the procedure.
Subject to the confidentiality requirements of internal investigations and their outcome, the whistleblower shall be kept informed of the course of the procedure.
How does the IT platform work?
Once started, the software will ask you to fill in a predefined form indicating the type of unlawful conduct, data on the time and place of the facts, the subjects involved, the level of involvement and direct or indirect knowledge of the facts on the part of the reporter, and thepossible involvement of other informed parties. It is also possible to upload documents in digital format (audio, photos, files, screenshots, etc.).
Even after you have sent your report, you can continue to communicate confidentially with the Reporting Manager by logging onto the platform using the code generated by the platform. Please remember to keep this code in a safe place, without which you will no longer be able to access the platform.
Reports and data entered into the platform cannot be deleted to ensure that your report cannot be deleted or modified by anyone: you will be able to access the platform at any time and see the status of your report. The platform encrypts all data entered by the reporter via a secure computer protocol (https). The identity and data provided during the reporting will therefore remain confidential for the duration of the investigation.
By accessing the platform, you acknowledge thePrivacy Policy Statement, pursuant to Art. 7 of the GDPR (679/2016), and give your free and informed consent to the processing of your personal data for the purposes, in the manner and within the limits set out in the policy.
For further details on the IT platform or the security measures adopted, please contact the Audit & Compliance department or the ICT department by writing to: internalaudit@enduranceoverseas.com or ict@enduranceoverseas.com.
Once the report has been made, is confidentiality protected?
Endurance is committed to ensuring that those who have made relevant reports, in the reasonable belief based on factual elements, are not subject to any kind of retaliation. In fact, specific measures are foreseen to protect the Whistleblower/Whistleblower, so that he/she is not subject to retaliation, discrimination or, in any case, penalisation connected to the report. These guarantees consist, on the one hand, in the prohibition of retaliation against whistleblowing by the employer, and, on the other hand, in the system of nullity of any retaliatory acts suffered in violation of this prohibition.
It should also be noted that the Decree allows the external reporting channelactivated by the national anti-corruption authorities to be used if the Whistleblower
- has already made an internal report and the same has not been followed up
- has well-founded reasons to believe that, if he/she were to make an internal report, it would not be effectively followed up or that the same report could give rise to the risk of retaliation
- has reasonable grounds to believe that the breach may constitute an imminent or obvious danger to the public interest.
