This procedure governs the protection in APG S.r.l. of persons who report breaches of Union law and national regulations pursuant to Legislative Decree no. 24 of 10/03/2023 implementing Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019.
The expression "whistleblower" means the employee or collaborator or self-employed worker or freelance professional or consultant or trainee or director who reports, to the body authorised to intervene, violations or irregularities committed to the detriment of the interest of APG S.r.l. or the Public Administration: the purpose of the report must be to bring to light and prevent risks and situations detrimental to APG S.r.l., the Public Administration and to respect the collective public interest.
The expression "whistleblowing policy", on the other hand, indicates the procedures for reporting as well as the actions provided for the protection of those who report wrongdoing.


The purpose of this procedure is, on the one hand, to remove any doubts and uncertainties on the part of the whistleblower as to how to make a report and, on the other hand, to dispel fears of retaliation or discrimination as a result of the report itself.
The procedure provides clear operational indications on
1. The subject of the report
2. Its content
3. The addressees of the report

4. The forms of protection provided to the "whistleblower"


The report may concern conduct, risks, offences or irregularities committed or attempted to the detriment of APG S.r.l. or the public interest. It may not, on the other hand, concern grievances of a personal nature on the part of the reporter or claims/claims falling within the scope of the employment relationship, or relations with the hierarchical superior or with colleagues.
In particular, the report may concern actions or omissions, whether committed or attempted:

1. Criminally relevant;

2. Committed in breach of the Codes of Conduct or other company provisions that may be subject to disciplinary sanctions;

3. Likely to cause financial damage to APG S.r.l;

4. Likely to damage the image of APG S.r.l.;

5. Able to cause damage to the health or safety of employees, users and citizens, or damage to the environment;
6. cause damage to users or employees or other persons carrying out their activities at APG S.r.l.


The report must contain all the elements necessary to ascertain the justification of the facts that are the subject of the report, in order to allow the competent manager to carry out the necessary checks.
In particular, as set out in the MODEL FOR THE REPORTING OF ILLEGAL CONDUCT, the report must contain:

□ The particulars of the person making the report, with an indication of the professional qualification or position;

□ The date and place where the fact occurred;

□ The assessment of the seriousness of the fact: whether the fact is criminally relevant, whether it may cause financial damage or damage to the image of APG S.r.l. or damage to health or the environment, etc;

□ The description of the fact (conduct and event);

□ The author of the fact (indicating the personal data, if known, and, if not, any other element useful for identification)

□ Any other persons aware of the fact and/or able to report on it

□ Reference to any documents and/or any other information that may confirm the validity of the facts reported.

The signature of the person making the report must appear at the bottom of the report, indicating the place and date.
Anonymous reports will only be taken into consideration if they relate to particularly serious facts and their content is adequately detailed and circumscribed.
The report must be made on the specific FORM FOR THE REPORTING OF ILLEGAL CONDUCT, attached to this procedure and available at


The above-mentioned report must be addressed to the Head of the Procedure for Reports of Offences, Ms Franzoni Ilaria: this documentation will be filed confidentially.
 The report may be submitted in the following ways

a) By sending it to the e-mail address
In this case, the identity of the person making the report will be known only to the person in charge of the procedure for reporting offences, who will guarantee its confidentiality, except in cases where it is not enforceable by law.

b) Verbally, by means of a statement made to the Whistleblowing Officer and recorded by him/her in the minutes.

c) Via the website in the Whistleblowing policy section, using the downloadable form to be sent by email to


The Head of the Whistleblowing Procedure issues the reporting person with an acknowledgement of receipt of the report within 7 days from the date of receipt, verifies the merits of the report through any activity he or she deems appropriate, including the personal hearing of the reporting person and of any other persons who may report on the facts reported, in compliance with the principles of impartiality and confidentiality, and provides feedback on the report within 3 months from the date of the acknowledgement of receipt.
In the management and verification of the merits of the report, the Head of the Whistleblowing Procedure may rely on the cooperation of the competent corporate structures.
If, once the verification activity is completed, the report proves to be well-founded, the Head of the Whistleblowing Procedure shall, depending on the nature of the report, proceed to

a) file a complaint with the competent judicial authority;

b) notify the outcome of the investigation to the Legal Representative of APG S.r.l., for the measures for which he is responsible, including disciplinary measures, if the prerequisites for disciplinary action exist, as well as any further action that may be necessary to protect APG S.r.l.


APG S.r.l. undertakes to:

□ Protect the confidentiality of the identity of the whistleblower,

□ Prohibit discrimination against the whistleblower;

With the exception of cases in which liability for libel and slander can be established in accordance with the provisions of the Criminal Code and cases in which anonymity cannot be enforced by law, the identity of the whistleblower is protected in any context subsequent to the report and cannot be disclosed without his/her express consent.
Whistleblowers who make a report under this procedure shall not be subject to any form of retaliation or discriminatory measure, whether direct or indirect, for reasons directly or indirectly linked to the report.
A whistleblower who considers that he/she has been discriminated against for having reported an offence must give detailed notice of the discrimination that has occurred to the Head of the Whistleblowing Procedure, who will assess the existence of the elements and then, in turn, report what has happened to the top management of the company, for the checks and measures falling within his/her competence.


This procedure is without prejudice to the criminal and disciplinary liability of the whistleblower in the event of a libellous or defamatory report under the Criminal Code and Article 2043 of the Civil Code.
Any form of abuse of this procedure, such as manifestly opportunistic reports and/or reports made with the sole purpose of damaging the whistleblower or other persons, and any other case of improper use or intentional exploitation of the institution covered by this procedure, shall also give rise to liability in disciplinary and other competent fora.