Our system for reporting illegitimate behaviors - "Whistleblowing"

D-Orbit is committed to promoting a corporate culture based on ethical behavior and good corporate governance, thus fostering an environment in which People are encouraged to report unacceptable conduct within the Group.

For this reason, specific channels, processes and procedures are in place at D-Orbit to ensure confidentiality and protection from any act of retaliation, discrimination or penalisation against people who report illegitimate conduct in good faith.

Violations and/or irregularities related to the issues governed by the regulatory provisions of Italian Legislative Decree no. 24 of 10 March 2023 concerning ‘the protection of persons who report breaches of EU law and containing provisions on protecting persons who report breaches of national laws’ transposing into Italian law the Directive (EU) 2019/1937 may be reported.

As an example, whistleblowing reports may include, but are not limited to, the following topics:

  • Bribery and corruption
  • Money Laundering
  • Violation of Financial Sanctions regulations
  • Violation of antitrust laws
  • Insider trading and/or market manipulation
  • Harassment
  • Bullying
  • Fraud
  • Misuse of confidential customer and Company data
  • Violation of the Code of Ethics and/or Code of Conduct
  • Violations of the Organization and Management Model pursuant to Legislative Decree 231/01

Reports should be submitted through the use of one of the following channels:

  • Filing a report through our dedicated Whistleblowing Platform at the following link: Whistleblowing Platform
  • Sending a written report to: D-Orbit S.p.A, Attn. Supervisory Body, Viale Risorgimento 57, 22073 Fino Mornasco, Como, Italy
  • Requesting a physical meeting to the Supervisory Body, Email: whistleblowing@dorbit.space

This Whistleblowing Platform is a dedicated IT tool that uses an encryption system to ensure the confidentiality of identity of the whistleblower, the person involved, the person mentioned in the report, the content of the report and the relevant documentation. This allows the competent office to communicate with the whistleblower by providing them with an acknowledgement of receipt of the report and feedback on the action taken or intended to be taken. You can find more clarifications on the correct use of the Whistleblowing Platform in the Procedure for managing reports of misconduct – whistleblowing hereby enclosed.

The channels mentioned cannot be used to propose a complaint regarding the business relationship, but only to report illegitimate behavior.

In compliance with the regulatory provisions of Italian Legislative Decree no. 24/2023 the office referred to in Art. 4, paragraph 2, appointed to carry out the activities referred to in Art. 5, was identified as the Whistleblowing Audit Committee already established within the Supervisory Body (Organismo di Vigilanza), which ensure that your information will be carefully considered and treated with absolute confidentiality.

External reporting channels

D-Orbit encourages People to use internal channels as a priority.

It should be noted that in Italy, in implementation of Italian Legislative Decree n. 24/2023, the National Anti Corruption Authority (ANAC) has been identified as the authority responsible for receiving and handling external reports, also anonymously.

The Whistleblower may therefore make an external report to ANAC if, at the time of its submission, one of the following conditions is satisfied:

  • There is no provision within his/her work context for the mandatory activation of the internal reporting channel, or this channel, even if mandatory, is not active or, even if activated, does not comply with the provisions of the law;
  • Has already made an internal report and it has not been followed up;
  • Has reasonable grounds to believe that, if it were to make an internal report, it would not be effectively followed up or that the same report could lead to a risk of retaliation;
  • Has reasonable grounds to believe that the violation may constitute an imminent or evident danger to the public interest.

In addition, the Whistleblower may also contact ANAC to notify any retaliatory acts resulting from a report.

External reports to ANAC may be made in the manner provided on the institutional website of the entity.