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Organisational and management models ex Legislative Decree 231/01Pursuant to art. 6, paragraph 3,of Legislative Decree no. 231 of 8 June 2001“Governing the Administrative liability of legal persons, companies and associations including those without legal status and associations including those without legal status, pursuant to art. 11 of the Delegated Law of 29 September 2000 No. 300”Consult the official documentation:

Modello di Organizzazione Gestione e Controllo SMN

Decreto 231

Reati Presupposto

Information on Whistleblowing

In compliance with Legislative Decree 24/2023 (the so-called “Whistleblowing Decree”) and in full compliance with applicable regulations, Officina Profumo Farmaceutica di Santa Maria Novella S.p.A. has adopted a whistleblowing procedure to help prevent offences and violations committed while working at Officina Profumo Farmaceutica di Santa Maria Novella S.p.A. 

Officina Profumo Farmaceutica di Santa Maria Novella S.p.A. guarantees protection of the identity of the whistleblower and of the people involved in and/or mentioned in the report, as well as confidentiality regarding its content. The Company also undertakes to implement every form of protection envisaged by the law against retaliatory or discriminatory conduct.

The content of the report, as well as any information traceable to the identity of the whistleblower, will be disclosed only to those individuals responsible for receiving or following up reports. Without the person’s express consent, no other party will have access to this information.

Who can act as whistleblowers?

According to the provisions of art. 3 of the Decree, those who can act as whistleblowers are:

- employees, also during their trial period, self-employed workers, as well as collaborators, freelancers and consultants who work at the Company;

- shareholders and those with administrative, management, control, supervisory or representative functions;

- trainees working for the Company;

- workers or collaborators of the Company's contractors, subcontractors and suppliers;

- former employees of the Company;

- candidates for a job at the Company, who have acquired information on the violations during the selection process or in other phases of the pre-contractual negotiation.

In other words, anyone who comes into contact with the Company in whatever capacity.

What can be reported by a whistleblower?

Matters that can be reported include behaviour, acts or omissions committed or which, based on concrete elements, could be committed within the working environment of Officina Profumo Farmaceutica di Santa Maria Novella S.p.A. in violation of national or European Union regulatory provisions referred to in art. 2 of the Decree, as well as violations of the Code of Ethics, of the Organisation and Management Model pursuant to Legislative Decree 231/2001, employment contracts and internal regulations (rules, policies, procedures, operating instructions, etc.).

For the sake of clarity, reports of infringements of antitrust law, as a set of European and national rules to ensure the protection of competition between companies, are included.

The report must be complete, exhaustive and detailed, so the whistleblower is required to provide all available elements that may be of use to allow appropriate checks and investigations needed to verify the matters being reported.

Internal reporting channels

For whistleblowers to make reports, Officina Profumo Farmaceutica di Santa Maria Novella S.p.A. has made available the following channels:

- online platform, accessible from the following link;

- ordinary mail, to be sent to: Officina Profumo Farmaceutica di Santa Maria Novella S.p.A. , Via della Scala n.16, 50123 – Florence (FI)– for the attention of the Supervisory Body;

- meeting directly with the Supervisory Body.

Note that the online platform makes it possible for reports to be transmitted both in writing and orally, in ways that also maintain anonymity.

The Supervisory Body receives and manages any reports that arrive, updating the whistleblower on the progress being made on the case
with the following timing:

- an acknowledgement of receipt is to be issued within 7 (seven) days of receiving the report; 

- within 3 (three) months from the date of acknowledgement of receipt or, in the absence of such notice, within 3 (three) months from expiry of the seven-day period from submission of the report, feedback is provided on the follow-up already given on the matter and which the Company intends to give in the future.

External reporting channels

In the exceptional cases provided for by the norm, and referred to (cf. art. 6 of Legislative Decree. 24/2023), the whistleblower - under his own responsibility - can send the report to the National Anti-Corruption Authority (ANAC) by means of the channels specifically made available by it.

How are personal data processed?

As part of the whistleblowing procedure, personal data are processed in compliance with current legislation (EU Regulation 679/2016 and Legislative Decree 196/2003, as amended by Legislative Decree 101/2018).

For further details on the processing of personal data, you can consult the Information on the processing of personal data of the person making the report and the person being reported on.

The above information, provided in compliance with current legislation, constitutes an extract of the Whistleblowing Procedure adopted by the Company.

Officina Profumo Farmaceutica di Santa Maria Novella S.p.A.

Registered Office

Via della Scala, 16

50123

Offices and Production

Via R. Giuliani, 141

50141 Firenze

VAT and Registration number at Business Register of Firenze 00459370482

R.E.A.  N. 1820

Share Capital Euro 2.100.000,00

Company under coordination and control of Italmobiliare S.p.A., VAT Number: 00796400158

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