Whistleblowing

Whistleblowing refers to reporting misconduct, unethical or illegal activities or violations of Nadara’s policies by anyone who has reasonable grounds to suspect that such behaviour is occurring.

You are entitled to raise any concerns about potential violations of legislation, regulations or of Nadara’s policies which could harm the public interest or the integrity of the company.

Some examples include: breaches of the Organisation, Management and Control Model (‘Modello Organizzati e di Gestione 231’, or ‘Manuales de prevención y detección de delitos’, or ‘Programa de Cumprimento Normative’, adopted respectively by internal entities located in Italy, Spain and Portugal); unlawful or irregular conduct (e.g. corruption, fraud, harassment, discrimination, conflicts of interest); violations in matters of health, safety, environment, data protection, competition or public procurement; omissions or abuses by individuals with managerial or supervisory roles, as well as any potential retaliation the whistleblower might suffer.

• Personal grievances (e.g. promotion requests, holidays, salary issues)
• Individual employment disputes (e.g. performance reviews, transfers)
• Unfounded reports or reports made in bad faith, based on rumours or lacking objective evidence
• HR or IT support requests not related to misconduct
• Reports already governed by sector-specific regulations with dedicated channels (e.g. national security, defence)

Different channels are available for you to report your concerns.

At your discretion, you can choose to raise your concerns through Nadara’s whistleblowing platform at https://whistleblowing.nadara.com/ where you will find explanations and be guided smoothly through the process, being the preferred channel.

Alternatively, you can send an email either to, [email protected] or directly to the General Counsel, the Chairman of the Risk & Audit Committee and/or the Chairman of the Board of Directors. General Counsel, the Chairman of the Risk & Audit Committee and/or the Chairman of the Board of Directors.

Ordinary mail to the attention of any of the above mentioned stakeholders is another possibility.

Finally, another option you have is to ask the Report Manager for a meeting where orally express your concerns.

Yes, the whistleblowing channel is managed by an external service provider proven to hold a high level of security safeguards and certifications. Additionally, the channel is not directly linked to Nadara’s system and only authorised people receive reports and have access to the relevant information.

Yes, you can decide not to disclose your identity. The system allows for anonymous reporting, providing you with a unique key-code to enable secure follow-up communication.

Your report should be as detailed as possible and include a description of the events, how you became aware of the facts, the identification and role of the person being reported as well as of any stakeholders who may be able to provide supporting information, as well as any further information which could help substantiate the reported events. Reports which lack sufficient detail or evidence may not lead to an investigation.

Considering the impact your report may have on Nadara employees or any third-party involved in the events, it is advisable to only report accurate information in those cases where you have reasonable suspicion and/or sufficient grounds to consider it to be true.

Once a report is submitted, an initial assessment takes place after which it might be dismissed if considered not sufficiently substantiated or, if proven to be well-founded, an action plan (including internal investigations, disciplinary measures, notifications to competent authorities etc.) will be drawn up to ensure an adequate response and outcomes are provided to the whistleblower. In any case, the whistleblower will receive a response within 3 months.

Yes, whistleblowers are protected from retaliation from reporting misconduct. As far as the whistleblower has a reasonable belief that the facts reported were true, occurred or could have occurred, and they report in good faith, the report will be considered a protected disclosure.