Brief guide for reporting to the supervisory board
BRIEF GUIDE FOR REPORTING TO THE SUPERVISORY BOARD AS PER ITALIAN LEGISLATIVE DECREE 231/2001 OF PALAZZO GRASSI S.P.A.
Anyone, including anonymously, may transmit reports on conduct that is in violation of the Code of Conduct and/or Organisation, Management and Control Model adopted by Palazzo Grassi S.p.A. pursuant to Legislative Decree 231/2001 (“Model 231”) or, of laws, regulations, provisions of Public Authorities and internal regulations, that can cause damage or detriment, even just its image, to Palazzo Grassi S.p.A. (“Reports”).
The Reports must be detailed and based on specific and consistent elements, regarding facts indicated and known directly by the Reporting Party, and must contain all of the information necessary for identifying the perpetrators of the wrongful conduct.
The Supervisory Board, as an independent and autonomous body of the Company, is the subject tasked with receiving, reviewing and assessing Reports which can be transmitted through the following communication channels:
- dedicated PEC (certified e-mail) mailbox (preferred channel), to the address of the Supervisory Board of Palazzo Grassi S.p.A. “odv.palazzograssi@legalmail.it”;
- confidential letter addressed to the “Supervisory Board of Palazzo Grassi S.p.A. based at "San Samuele, 3231 - 30124 Venezia".
Before sending a Report, the Reporting Party is asked to read the Privacy Policy present in the following point on the LEGAL NOTICES AND CREDITS page of the Website of Palazzo Grassi - Punta della Dogana.
The contents of the Report and the Reporting Party’s identity shall only be accessible to the Supervisory Board, which is assigned with receiving the same or the subjects tasked with later inquiry regarding the reported facts, who guarantee its confidentiality.
Any abuse of the Reporting System is prohibited in order to protect the Reported Party. To this end Reports as follows are strictly forbidden:
- of abusive, libellous or slanderous nature towards the Reported Party or distribution of his personal information, including sensitive, which concerns solely aspects of private life, without any direct or indirect connection with the Reported Party’s company/professional activity, which may imply a damage to his reputation, discrimination, retaliations or other disadvantages;
- which may give rise to civil and/or criminal liability for the Reporting Party.
Specifically, the Reporting Party must be aware that:
- the Report does not guarantee any protection to the Reporting Party if he was party to the wrongful conduct;
- without prejudice to the Reporting Party’s criminal, civil or disciplinary liability, in the case of a slanderous or libellous Report, Reports sent with wilful intent or gross negligence, opportunistic Reports and/or made for the sole purpose of harming the Reported Party, as well as all other cases of abuse or exploitation liable to disciplinary sanctions;
- personal complaints cannot be the subject matter of a Report.
The behaviour of anyone who makes Reports with wilful intent or gross neglect that turn out to be groundless is punishable.
Every Report received is assessed and reviewed by an autonomous and independent party (Supervisory Board) not directly involved in the reported event, in order to avoid conflicts of interest or absence of impartiality.