Imprint

VSB Energia Verde Italia S.R.L.

Via della Chimica, 103
85100 Potenza
Italy

Telephone: +39 0971 281981
E-Mail: italia@vsb.energy

Certified E-mail address: vsbenergiaverde@pec.it

VAT number: 01350850119
Economic and Administrative Index no.: PZ142820
Share capital €20,000.00

Information, Training and Publication – Model 231 VSB ITA

VSB Energia Verde Italia S.r.l., in pursuing the management of its business activities based on the values of efficiency, fairness, and integrity in every aspect of its operations, with the aim of:

ensuring the integrity of the company by strengthening the internal control system;
improving the effectiveness and transparency in the management of corporate activities and ensuring compliance with the obligations set forth by the Decree;
promoting awareness of the principles of transparency and fairness among all individuals collaborating, in any capacity, with VSB Energia Verde Italia S.r.l.,

>on January 12, 2023, decided to adopt its own Organization, Management, and Control Model in accordance with the provisions of Legislative Decree no. 231/2001.

Accordingly, an internal body named the Supervisory Board (Organismo di Vigilanza) has been established, entrusted with the task of monitoring the functioning of and compliance with the Model.

Compliance with the Model and the related Code of Ethics is mandatory for all those who operate with the company — including members of the corporate bodies, employees, collaborators, and third parties — who must adhere to it in the performance of their duties or professional mandates.

Reports to the Supervisory Board regarding any behavior that may constitute a violation of Model 231 can be submitted via email at: odv231@vsb.energy

WHISTLEBLOWING REPORTS

In accordance with Legislative Decree No. 24/2023, VSB Energia Verde Italia Srl (hereinafter also referred to as the “Company”) has implemented its own whistleblowing reporting channel.

WHO CAN SUBMIT A REPORT?

Reports, which will be handled in compliance with Legislative Decree No. 24/2023, may be submitted by:

employees;
workers with part-time, intermittent, fixed-term, temporary agency, apprenticeship or ancillary employment contracts;
workers performing occasional services;
self-employed workers providing their services to the Company;
freelancers and consultants providing their services to the Company;
volunteers and trainees, whether paid or unpaid, providing their services to the Company;
suppliers of goods and services to the Company;
shareholders;
persons who, even de facto, perform functions of administration, management, control, supervision or representation of the Company.

WHAT CAN BE REPORTED?

Reports may concern information on violations of national or European Union regulatory provisions that harm the public interest or the integrity of the Company, of which the reporting person has become aware in the course of their work-related activities.

The following do not qualify as whistleblowing reports:

complaints, claims or personal requests relating to one’s own employment relationship (to be addressed to the competent corporate functions);
complaints or disputes relating to services provided by the Company (to be addressed to the competent corporate functions).

HOW TO SUBMIT A REPORT?

INTERNAL REPORTING CHANNELS

Reports may be submitted through the dedicated Whistleblowing IT tool, accessible by clicking here [VA1] .

The tool allows reports to be submitted in written form, with the possibility of uploading videos and photos, as well as by requesting a meeting with the Internal Reporting Channel Manager.

WHO IS THE INTERNAL REPORTING CHANNEL MANAGER?

The person responsible for receiving and managing reports is the Internal Reporting Channel Manager.

The Internal Reporting Channel Manager may be supported by specifically authorised internal resources, appointed through a written communication.
Furthermore, in carrying out the investigation, the Internal Reporting Channel Manager may be supported by the relevant internal corporate structures from time to time, or by external professionals appointed for this purpose.

EXTERNAL REPORTING CHANNEL AND PUBLIC DISCLOSURE

The internal reporting channel must be used as a priority.

Reporting persons may use the external channel managed by ANAC, by accessing
https://www.anticorruzione.it/-/whistleblowing, exclusively in the following cases:

the Company has not activated an internal reporting channel or such channel is not compliant with Legislative Decree No. 24/2023;
a report has already been submitted via the internal channel, but no follow-up has been provided;
the reporting person has reasonable grounds to believe that, if the internal channel were used, the report would not be effectively addressed or the reporting person could be subject to retaliation;
the reporting person has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest.

Reporting persons may also make a public disclosure (press and other means of dissemination, such as social networks) if one of the following conditions applies:

the reporting person has previously submitted an internal and external report, or has directly submitted an external report, and no feedback has been provided within the established time limits regarding the measures envisaged or adopted to follow up the reports;
the reporting person has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest;
the reporting person has reasonable grounds to believe that the external report may entail a risk of retaliation or may not receive effective follow-up due to the specific circumstances of the case, such as situations where evidence may be concealed or destroyed, or where there is a reasonable suspicion that the recipient of the report may be colluding with the perpetrator of the violation or involved in the violation itself.

The right to report violations to the competent national judicial and accounting authorities remains unaffected.

In implementation of the above, VSB Energia Verde Italia Srl has adopted the “Whistleblowing Procedure”, which can be consulted here.

For a comprehensive analysis of:

the persons entitled to submit reports;
the subject matter of reports;
the reporting channels;
the procedures for handling reports;
the protections granted to reporting persons, persons reported in bad faith, and other individuals identified by law,

as well as for all matters not covered by this notice, reference should be made to the Procedure.

For the privacy notice, click here.