Organization
Midac operates in accordance with the Organization management and control Model pursuant to Legislative Decree. n. 231/2001 (concerning “administrative responsibility” of legal entities, below, hereinafter “Compliance Program” or “Program”). The adoption of the Program allows the company, in compliance with the provisions of law, to strengthen its internal control system (inspired by principles of fairness and transparency) and to protect itself, in case “relevant” crimes subject to the application of the previsions in Legislative Decree 231/01 are committed. The model consists of three parts: A) General Part; B) Code of Ethics (and behavior); C) Special Section (concerning “relevant” crimes). The Program explicitly refers to the Code of Ethics of Midac S.p.A. which identifies the reference corporate values, highlighting the rights, duties and responsibilities of all who, on whatever basis, operate within the company or cooperate with it.
The adoption of the Program involved the appointment of a Supervisory Board (hereinafter “S.B.”), responsible for supervising the functioning and observance of the Program, as well as its updating, the S.B. is provided with independent powers of initiative and control.
In order to establish an appropriate information flow to the S.B., by transmitting to it all significant information (as indicated in the Program) from any subject, the following e-mail address has been set up: organismodiviglianza@midacbatteries.com. The access to the mentioned account is exclusively reserved to the S.B.and can be used by people who are aware of relevant information, for the purposes above specified, without fear of retaliation. In order to perform its duties the S.B. will handle the received information, in compliance with the legislation on protection of personal data (Legislative Decree n. 196/2003) and with the appropriate level of confidentiality. No reports must be made for the sole purpose of retaliation or emulative (ie. designed to harm third parties).
Code of Ethics
The Legislative Decree 231/2001 regulates the administrative liability of legal entities such as companies, associations and institutions. The adoption of a code of ethics is a guarantee of good behavior, loyalty, fairness; the company takes the challenge, it becomes one with its employees.
Apart from the general principles of respect for the law, the Code of Ethics gives prominence to the objectives of sustainable development, including the responsibilities towards the territories in which it operates, the protection of third-generation rights, and the defense and promotion of Human Rights.
Whistleblowing
For Midac S.p.A., compliance with laws and regulations, internal company protocols, as well as the principles and values expressed in the Code of Ethics, is the responsibility of everyone: both those who work in the company and third parties.
Midac S.p.A. supports and encourages anyone wishing to report a potential conduct of alleged violation of laws and regulations and/or the principles expressed in the Code of Ethics and the Organizational Model pursuant to Legislative Decree 231/2001.
In this context, and in compliance with regulatory provisions, Midac S.p.A. has established a secure and confidential channel for Reporting, through a dedicated form available on the reporting management portal, accessible at the following link:
https://areariservata.mygovernance.it/#!/WB/midac
The whistleblowing Reporting system is one of the most effective tools for identifying unlawful conduct and for offering employees and all stakeholders (partners, customers, suppliers, consultants, collaborators, and, more generally, any third party with knowledge of non-compliant conduct) the opportunity to report violations they become aware of.
The Reporter may report violations of any nature, whether a behavior or an omission, that may constitute offenses even if only potentially contrary to legal regulations and internal rules of the company. However, communications relating to personal matters and reports based on mere suspicions or rumors concerning personal facts not constituting an offense are excluded.
If, following a preliminary check, the Report, even if anonymous, is found to be substantiated, investigative activities will be carried out to ascertain the validity of the reported facts.
Midac S.p.A. ensures the confidentiality of the Whistleblower’s identity and the confidentiality of the information contained in the Report throughout the case management process. Midac S.p.A. is committed to protecting the Whistleblower acting in good faith against any form of retaliation, discrimination, or penalty for reasons directly or indirectly related to the Report.
As part of the reporting management process, personal data is processed in compliance with current legislation (EU Regulation 679/2016 and Legislative Decree 196/2003, as amended by Legislative Decree 101/2018).
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