Are you an employee or supplier of Blu Navy and wish to report misconduct and/or irregularities?

BN di Navigazione S.p.A., with the implementation of the provisions of the new Whistleblowing discipline (d.lgs.24/2023 implementing EU Directive no. 1937/2019), makes available to its employees, reporting methods for collaborators, business partners, suppliers, and other parties who wish to submit detailed reports of relevant illicit conduct of which they have become aware due to their roles and which may seriously threaten BN di Navigazione S.p.A.’s reputation.

In light of the aforementioned regulatory provision, BN di Navigazione S.p.A., already equipped with an Organizational, Management, and Control Model pursuant to D. Lgs. 231/2001 (Model 231), has adapted Model 231 itself and revised the reporting system, coordinating the reporting system already in use with the new regulatory requirements.

The aim is to enable BN di Navigazione S.p.A. to manage the report in accordance with the timeframes set by the regulations, making situations of risk or damage known and thus contributing to the prevention and counteraction of any wrongdoing.

Through appropriate channels and methods that guarantee protection and confidentiality to the reporter, all stakeholders can contribute to countering illicit behavior.

The channels that the Company has adopted guarantee that the Report and the reporter’s identity cannot be accessed by the Reported Party and by third parties who have not been identified by the organization as recipients of the reports or as subjects responsible for the subsequent investigation into the reported facts.

Anyone who becomes aware directly in the course of their work duties of any anomalies, serious irregularities, or violations of BN di Navigazione S.p.A.’s organizational model, can make a report, even anonymously, to the Responsible Management Office through these channels:

The report will be managed confidentially by the relevant office, which is required not to disclose the possible identity of the reporter. Any personal data present is processed in compliance with current Privacy regulations and retained for the strictly necessary period for report management.

BN di Navigazione S.p.A. strongly encourages reporting any improper, dishonest, or potentially illegal activity, as well as behaviors that may cause harm or damage, including to the company’s image. To this end, BN di Navigazione S.p.A. has implemented specific rules and a whistleblowing process to provide potential reporters with secure channels that guarantee the confidentiality of their identity and the information contained in the report and protect them from potential retaliation.

Reports other than those described above will not be considered, particularly those related to requests and complaints of a commercial nature. In the case of unfounded reports made in bad faith or with gross negligence, BN di Navigazione S.p.A. reserves the right to take action to defend its own interests or those of the injured parties. N.B: Reports cannot be based on “mere” rumors or hearsay but must contain specific elements useful for ascertaining the veracity of the reported facts, allowing the company to carry out the necessary verifications. The following are not part of the reports: mere suspicions or rumors, personal grievances of the reporter, claims related to the employment or collaboration relationship or relationships with superiors or colleagues. The reporting system cannot be used to make false accusations against third parties, and, in general, intentionally inaccurate information cannot be reported. The report must provide all the necessary and appropriate elements to allow an appropriate assessment of its veracity. In the case of a verified report, Management will take appropriate disciplinary measures and, in any case, actions to protect the company.

The report is handled with the utmost confidentiality, following the procedures outlined in the appropriate Procedure, and the identity of the reporter, when declared by the reporter, is not disclosed, subject to legal obligations. Any retaliatory or discriminatory actions against the reporter for reasons connected, directly or indirectly, to the report are prohibited. Disciplinary sanctions are provided for those who violate the measures protecting the reporter.

The reported party cannot be subject to disciplinary sanctions based on what is stated by the reporter without objective evidence and without an investigation into the reported facts. Even reports made in bad faith, opportunistically, as well as unfounded reports made with gross negligence, are also a source of liability, both in disciplinary proceedings and in other competent fora.

Information regarding the processing of personal data provided by you at the time of reporting and subsequently acquired during the investigation, which will be processed, also by electronic and computer means, exclusively by the Officer responsible for receiving and managing reports designated for this purpose.