Group whistleblowing procedure

A key tool used to enforce compliance and internal control, as well as prevent risks, is represented by the Group Whistleblowing Procedure. This procedure is used to handle reports of possible cases of corruption or violation of the principles and/or precepts set out in the Ethical Code – including equal opportunities – statutes and regulations.

The Whistleblowing Procedure, which has been distributed to all employees in their local languages, spells out how to report violations, suspected violations and inducement to commit violations of laws and regulations, the principles set out in the Ethical Code, internal control principles, corporate rules and procedures, or any other acts or omissions that might cause direct or indirect financial damage or harm to the image of the Group and/or its subsidiaries.

The Procedure explicitly encourages employees who are aware of potential or actual violations to report them immediately to the Company, either anonymously or openly.
They are guaranteed the absolute confidentiality and protection from reprisals of any sort.

These reports may involve Company directors, statutory auditors, management and employees, as well as anyone else who operates inside or outside Italy on behalf of the Pirelli Group or has business relationships with the Group. This includes partners, customers, suppliers, consultants, independent contractors, accounting firms, and public institutions and entities.

The e-mail box and telephone and fax numbers are managed at the corporate level by the independent Internal Audit Department and are to be used by all Group affiliates.

The Pirelli Internal Audit Department is responsible for:

  • setting up, managing and updated the addresses for sending communications; receiving, registering and analysing the received reports by engaging the participation of other corporate departments and offices for investigation as necessary and forwarding any reports to the supervisory bodies with jurisdiction according to the situations were a specific supervisory body exists (for Italian companies: the Board of Statutory Auditors, the Supervisory Bodies for offences pursuant to Legislative Decree 231/01);
  • preparing specific action plans;
  • ensuring the retrieval and storage of documentation for five years after the conclusion of the investigation;
  • filing a quarterly report with the Internal Control Committee of Pirelli & C S.p.A. on reports received and actions underway.

If it is ascertained that the report is valid, the Company must take appropriate disciplinary measures and legal action to protect itself and the Group, if necessary.

In February 2012, the Whistleblowing Procedure was being revised and updated in order to improve the efficiency of the reporting process even further. Once this procedure is completed in 2012, it will be adequately distributed to Pirelli employees.

In 2011, the Whistleblowing Procedure was activated twice, following an anonymous report of presumed conduct in violation of Company rules and procedures, particularly in regard to the internal rules that govern fair, transparent remuneration policies and purchasing processes. The analyses carried out by the Group Internal Audit Department did not reveal conduct confirming the allegations made in that anonymous report. The other report made at the end of 2011 is still under investigation.