WHISTLEBLOWING – VIOLATION REPORTS
In accordance with Legislative Decree 24 of March 10, 2023, Match encourages anyone in the work context who becomes aware of potential violations of the Organization, Management, and Control Model pursuant to Legislative Decree 231/2001, the Code of Ethics, or other potential violations of the law that could jeopardize Match’s business or reputation or cause harm to third parties, to report them.
REQUIREMENTS OF THE REPORT
Every report must contain the following elements:
· Personal details of the Whistleblower (however, the option for anonymous reports is also available);
· A clear and comprehensive description of the reported facts;
· If known, the time and place where the events occurred;
· If known, the personal details or other identifying elements (such as job title and department) of the individual(s) involved in the reported facts;
· Indication of any other individuals who can provide information regarding the reported facts;
· Indication of any documents that can corroborate the reported facts, preferably attached to the report;
· Any other information that may provide useful verification regarding the reported facts.
It is specified that:
· Reports based solely on mere rumors or unreliable hearsay will not be taken into consideration;
· Anonymous reports are within the scope of this document only if they meet the aforementioned requirements;
· Reports concerning disputes, claims, or requests related to the Whistleblower’s personal interests solely concerning their individual work relationships are not permitted. This includes, for example, employment disputes or conflicts between colleagues.
INTERNAL REPORTING CHANNELS
Reports can be submitted using one of the following internal reporting channels:
• Mail: Match S.r.l., via Privata Grosio 10/10 – 20151 Milano
For the attention of: “Organismo di Vigilanza” with the words «Riservata Personale»
• Web: through Iubenda software platform – written or oral reports
Additionally, oral reporting is allowed, upon the Whistleblower’s request, through a direct meeting with the Supervisory Body, to be arranged through the aforementioned channels.
Each report will be assessed to determine if it is suitable for management.
Reports will always be managed ensuring the confidentiality of the Whistleblower and the absence of retaliation against them.
In the case of anonymous reports, the Whistleblower may be requested to disclose their identity, always with the guarantee of confidentiality and protections provided by EU Directive 2019/1937 on Whistleblowing.
EXTERNAL REPORTING CHANNELS
In certain cases, it is possible to submit the report to ANAC (Autorità Nazionale Anticorruzione – National Anti-Corruption Authority).
This can ONLY be done IF one of the following conditions is met, and the Whistleblower must have evidence to support it:
• the Whistleblower has previously made an internal report, and it has not been acted upon;
• the Whistleblower has reasonable grounds to believe that, if they were to make an internal report , it would not be effectively followed up, or that it would result in retaliatory actions;
• the Whistleblower has reasonable grounds to believe that the violation may pose an imminent or manifest danger to the public interest.
Finally, recourse to public disclosure through the press or electronic media or means of dissemination is ONLY permissible IF one of the following conditions is met, and the Whistleblower must have evidence to support it:
• the Whistleblower has previously made an internal report and reported to ANAC, or has directly made an external report to ANAC, and has not received a response within the specified time frame regarding the measures taken or adopted to address the report;
• there are reasonable grounds to believe that the violation may pose an imminent or manifest danger to the public interest;
• there are reasonable grounds to believe that an external report may entail the risk of retaliation or may not be effectively followed up due to specific circumstances of the particular case, such as situations where evidence may be concealed or destroyed, or where there is a reasonable fear that the recipient of the report may be colluding with the violator or involved in the violation itself.
DOCUMENTATION
The Whistleblowing documentation of Match S.r.l. is available at the following links: