Internal Alert Procedure (Whistleblowing) of the Fondazione Teatro Donizetti

The “Internal Alert Procedure” (also known as “whistleblowing“) is a tool for prevention and correction of acts or facts that may constitute unlawful conduct as defined by external and internal regulations (such as the Code of Ethics), harmful to the public interest or the integrity of the private entity. It encourages and protects the positive behavior of staff or other legitimate subjects identified by the regulations who, having become aware of the illegality or illegitimacy of another person’s actions in the workplace, decide to confidentially report such acts or facts to the appropriate bodies.

An effective whistleblowing system represents an important tool for the Foundation to consistently uphold the standards of transparency and integrity in its actions and serves as a useful early warning system that allows for the adoption of appropriate measures.

Reports can be submitted to the internal alert procedure by employees and those who operate based on relationships that determine their inclusion in or connection with the organization, even in forms other than subordinate employment, such as:

• self-employed workers, outsourced workers and collaborators, freelancers and consultants who work for the Group;
• volunteers and paid and unpaid interns;
• shareholders and persons with administrative, management, control, supervisory or representative functions;
• staff of suppliers outside the Foundation.

Reports may concern offenses under Legislative Decree 24/2023 (such as environmental protection, public procurement, protection of privacy, protection of personal data, security of networks and information systems, etc.), potential or actual violations of the provisions dictated for the prevention of money laundering and financing of terrorism as provided by Art. 48 of Legislative Decree 231/2007, any other unlawful conduct under Legislative Decree 231/01 as well as any violation of the organizational model adopted by the Foundation.

The Foundation protects the reporter “against retaliatory, discriminatory or otherwise unfair conduct resulting from the report,” in a climate of respect for the reporter’s dignity.