Colpack manufactures regenerated polyethylene bags for separate waste collection, combining innovation and technology to ensure high performance even for customized solutions. Customers worldwide choose us for our expertise and reliability.

Whistleblowing Policy

Who can report?

The following individuals are entitled to report violations they have become aware of within their work context:

  • employees, regardless of contract type;
  • self-employed workers;
  • collaborators, freelancers, and consultants;
  • volunteers and interns, including unpaid;
  • shareholders (natural persons);
  • individuals performing functions of administration, management, control, supervision, or representation, even on a de facto basis.

More generally, all the Company’s stakeholders.

When can a report be made?

A report may be made:

  • during the employment or professional relationship;
  • before the relationship has started, if the information was acquired during the recruitment process or pre-contractual stages;
  • during the probation period;
  • after the termination of the relationship, if the information was acquired before its termination.

What can be reported?

Reports may concern acts, behaviors, or omissions including:

  • violations of European Union law in specific areas (including public procurement; product safety and compliance; environmental protection; public health; consumer protection; personal data protection; information system security);
  • acts or omissions affecting the financial interests of the European Union or the free movement of goods, persons, services, and capital (e.g. competition law or State aid violations);
  • predicate offences pursuant to Legislative Decree 231/01;
  • violations of the Organizational Model adopted under Legislative Decree 231/01.

Reports may also concern actions aimed at concealing such violations, as well as violations not yet committed that the reporting person reasonably believes may occur based on concrete elements.

What cannot be reported?

The following cannot be reported:

  • complaints, claims, or requests related to a personal interest concerning individual employment relationships;
  • violations already regulated by EU directives/regulations or Italian law that provide specific reporting procedures;
  • national security matters and defence-related procurement, unless covered by relevant EU law;
  • manifestly unfounded information;
  • information already fully in the public domain;
  • information based solely on rumors or unreliable hearsay.

How can you submit a report?

In compliance with applicable legislation, Colpack S.r.l. has implemented an internal reporting channel through an IT platform compliant with Legislative Decree 24/23, accessible at:

https://colpack.whistlelink.com

and via the dedicated “Whistleblowing” section on the Company website:

https://www.colpack.com/segnalazioni-whistleblowing/

Through the platform, reports can be submitted either as a written report via a guided form or as a voice recording (maximum duration: 10 minutes).

In both cases, supporting documents may be attached and it is possible to request a confidential meeting with the report handler.

Reports must always be detailed and well-founded.

Using a unique identification code and password generated by the platform, the reporting person can track the status of their report and communicate with the report handler.

What guarantees does Colpack provide?

Colpack S.r.l. guarantees the confidentiality of the reporting person’s identity, the individuals involved, and the content of the report.

The Company ensures protection against any form of retaliation or discrimination, whether direct or indirect, including attempted or threatened actions.

Support measures are also available through third-sector entities listed by ANAC.

Protections also apply to individuals connected to the reporting person, including:

  • facilitators assisting in the report;
  • colleagues in the same work context;
  • relatives or close persons;
  • entities owned by or linked to the reporting person.

How are reports managed?

The reporting process is handled by an independent and specifically trained report handler.

The handler will diligently follow up on reports, verifying their content and carrying out internal investigations to assess their validity and adopt appropriate measures.

The reporting person will be informed of receipt and outcome.

  • acknowledgment of receipt within 7 days;
  • ongoing communication with the reporting person;
  • feedback within 3 months.

Other reporting channels

ANAC external channel

An external reporting channel is available through the Italian Anti-Corruption Authority (ANAC).

This can be used only if:

  • the internal channel is unavailable or non-compliant;
  • an internal report has not been followed up;
  • there is a risk of retaliation;
  • there is an imminent risk to the public interest.

Public disclosure

Information may be disclosed publicly (e.g. via media or social networks) only under specific legal conditions.

Judicial report

The reporting person may also report directly to judicial authorities.

Loss of protection and liability

The reporting person must reasonably believe that the reported information is true.

Protections do not apply in cases of false reporting made with intent or gross negligence.

Sanctions may include disciplinary measures and administrative fines from €500 to €2,500 imposed by ANAC.