1.Legal References

Whistleblowing was introduced in Italy at the end of 2017 with Law No. 179/2017, later superseded by Legislative Decree No. 24/2023, which transposes EU Directive 2019/1937 on the protection of persons who report breaches of Union and national law.

Educa International School Versilia S.r.l. adopts this procedure because it falls under the obligation set out in Legislative Decree 24/2023, having employed an average of at least 50 workers over the previous year, in order to guarantee a secure, confidential and protected channel for reporting unlawful conduct encountered in the course of work.

2.Who Can Make a Report

Under Legislative Decree 24/2023, reports may be made by:

• employees and collaborators of the school;
• suppliers, contractors and their employees/collaborators;
• freelancers and consultants;
• volunteers and trainees, whether paid or unpaid;
• shareholders or persons with administrative, management, supervisory or representative functions;
• former employees or collaborators whose relationship with the school has ended;
• persons whose legal relationship with the school has not yet begun, if the information was acquired during the selection process or other pre-contractual stages.

The procedure also protects the identity of anyone who assists a reporting person within the same work context.

3.What Can Be Reported

Unlawful acts of which a person becomes aware in the context of their work activity must be reported under this procedure. Well-founded suspicions of offences or other violations of the law, or concrete risks that such conduct may occur, may also be reported, including criminal, civil, administrative or accounting offences, as well as breaches of EU regulations.

The reporting person is not required to provide full proof of the offence, but the report should be as detailed as possible, to allow the facts reported to be properly assessed.

4.Whistleblowing Manager

At the end of the assessment, the manager communicates the outcome to the reporting person, which may include: correction of internal processes, initiation of disciplinary proceedings, referral of the matter to the Public Prosecutor's Office, or closure for lack of evidence.

5.Reporting Channels

Reports may be made in writing or orally:

• Written reports: admin@eisversilia.it. We recommend adopting a dedicated, encrypted IT platform to ensure the highest level of technological confidentiality, as envisaged by Legislative Decree 24/2023.
• Oral reports: by requesting a telephone or in-person interview with the whistleblowing manager. Oral reports are recorded, and the written minutes must be signed by the reporting person to be processed.

A report sent by mistake to a line manager instead of the dedicated channel is not treated as a whistleblowing report for the purposes of the confidentiality protections set out in this procedure.

6.Timing of Handling Reports

• Within 7 days of receipt, the manager confirms to the reporting person that the report has been received and is being handled;
• within 3 months of the report, the manager provides feedback on the verification activities carried out.

7.Confidentiality

The manager is required to treat reports with the utmost confidentiality. The identity of the reporting person, the reported person and any other individual mentioned in the report, as well as the content of the report itself, may not be disclosed without the reporting person's consent, except where knowledge of the identity is essential to the reported person's right of defence in judicial proceedings.

Anonymous reports may be submitted; however, in such cases the school will not be able to provide direct feedback to the reporting person, and protection against retaliation can only be guaranteed if the identity is later established and the report otherwise meets the requirements of this procedure.

8.Protections and Prohibition of Retaliation

The reporting person is protected against any form of retaliation or discrimination arising from a report made in good faith, even where the report proves, following investigation, to be unfounded. Examples of prohibited retaliation include: dismissal, suspension, demotion, change of duties, reduction of salary, harassment, negative performance notes, or any other unfavourable treatment connected to the report.

Reports made with intent or gross negligence, or that prove to be defamatory or slanderous, may instead be subject to disciplinary action against the reporting person, as provided for under Legislative Decree 24/2023.

9.External Reporting Channels

In addition to the internal channel, a reporting person may contact the National Anti-Corruption Authority (ANAC) directly where: the internal channel is not active or has not acted on the report; there are well-founded reasons to believe an internal report would not be effective or would expose the person to a risk of retaliation; or there is an imminent and clear danger to the public interest.

External reporting procedures: anticorruzione.it/-/whistleblowing