Primo Capital SGR S.p.A. (“Primo Capital”) supportsand encourages anyone wishing to report potential inappropriate or improperconduct, or suspected breaches of laws and regulations, as well as of theprinciples set out in the Company’s policies and procedures, in order to upholdthe values of integrity and ethical behaviour.
Primo Capital believes in this mechanism, whichstrengthens the internal control system already in place and subject tocontinuous improvement, and considers reporting to be an expression of civicresponsibility that helps to bring to light and prevent situations thatundermine good governance and, more generally, the collective public interest.
Primo Capital has adopted the “WhistleblowingProcedure” to govern the operation of the Reporting Channel and the protectionregime for individuals who report inappropriate or improper conduct, or suspectedbreaches of laws and regulations, as well as any behaviour that may havenegative effects on our company, on people’s well-being and/or the protectionof the public interest.
The Whistleblowing Procedure is intended to describeand regulate the objective and subjective scope of the Reporting Channel, aswell as its management, in order to enable the designated person to assess thevalidity of the internal reports received.
Reports must be detailed, based on factual evidence,precise and consistent, and as complete and as comprehensive as possible. Thereporting system must not be used to make mere complaints or false accusationsagainst third parties and, moreover, deliberately inaccurate information mustnot be reported.
Anonymous reporting is allowed.. The procedure and thesystem in place guarantee, in all cases, the confidentiality of the informationprovided in the report. For further information, please refer to the PrivacyNotice included in the reporting form.
Reports may be submitted, either verbally or inwriting, via the Whistleblowing Portal, which is accessible from both personalcomputers and mobile devices 24 hours a day, 7 days a week, via the following link:
The Portal is hosted entirely on an infrastructureexternal to Primo Capital, designed, developed and managed to ensure theconfidentiality of the Whistleblower’s identity and the protection of thePersons Involved and the Person Reported, in compliance (among other things)with applicable data protection legislation.
For further details, please find attached PrimoCapital’s Whistleblowing Procedure.
