The Group’s Whistleblowing Policy completes the system of compliance and internal control. It is intended for Employees, and Stakeholders external to the Company.
The Policy - communicated to all employees in their local language and made available to the wider Community at Pirelli’s website - governs the methods used to report violations, suspected violations and inducements to violations of laws and regulations, principles which are enshrined in the Code of Ethics - which include, of course, equal opportunities - principles of internal control, company standards and procedures, or any other act or omission that may directly or indirectly lead to economic or asset damage, or damage to the image of the Group and/or its subsidiaries.
The Whistleblowing Reporting channel is also expressly mentioned in the Sustainability Clauses that are inserted in every supply contract.
Reports may also be done anonymously, and it is emphasised that there is a strong guarantee of absolute protection of confidentiality as well as there being intolerance of retaliation of any kind.
Reports may relate to Directors, Auditors, Management, employees of the Company and, in general, to all those who work for Pirelli in Italy and abroad, or that have business relationships with the Group. This includes partners, customers, suppliers, consultants, collaborators, auditing firms, institutions and public bodies.
The e-mail inbox at email@example.com is available to those wanting to make a report, and is centrally managed by the independent Internal Audit Department, and applies for all the subsidiaries of the Group as well as for the wider community.
This The Group’s Internal Audit Division is responsible for analysing all of the reports received, including via involvement of the corporate departments and offices deemed competent for checking such; for scheduling specific action plans; and for reporting, at least quarterly, to Pirelli & C.’s ARSCGC with regard to reports received and actions in progress.
If it is ascertained that a report is founded, there is provision for adopting the appropriate disciplinary and/or legal action to safeguard the company.
With reference to reports received in the years 2014, 2013 and 2012, below is a table summarising these, followed by greater detail on the 2014 reports.
|Of which were anonymous||9||6||3|
|Of which were shelved due to absolute vagueness||12||3||2|
|Of which were founded||8||8||6|
|The report’s country of origin||Brazil, Egypt, Romania, Poland, Argentina, Russia, Peru, Saudi Arabia, Germany, USA, South Africa||Italy, Brazil, Argentina, Venezuela||Italy, Brazil, Egypt, Poland, Mexico|
|Allegation made in the report||Irregular behaviour of employees, one case of poor customer service, and one case against a supplier||Irregular behaviour of employees, one case of poor after-sales service||Irregular behaviour of employees, one union claim, one case of discrimination|
|Outcome of the cases investigated||Review and integration of processes where deemed appropriate, measures on the part of the relevant departments and the Human Resources Department, actions to the satisfaction of the customer and the supplier||Review and integration of processes where deemed appropriate, measures on the part of the relevant departments and the Human Resources Department, actions to the satisfaction of the customer||Review and integration of processes where deemed appropriate, measures on the part of the relevant departments and the Human Resources Department, actions to the satisfaction of the customer|
The increase in reports during the three-year period may be attributed to repeating the communication campaign to employees, in the local language, regarding the existence of the procedure and how to activate it.
During 2014, the Whistleblowing procedure was activated 23 times. Specifically:
- the 23 reports came from 11 different countries (Brazil, Egypt, Romania, Poland, Argentina, Russia, Peru, Saudi Arabia, Germany, USA, South Africa)
- 39% of the reports (9 cases) were submitted using the Group’s appropriate electronic mail inbox for Whistleblowing firstname.lastname@example.org, while 61% (14 cases) sent a letter to management which took steps to inform the Internal Audit Department in accordance with company regulations.
- 61% of the reports (14 cases) were signed while the remaining 39% (9 cases) were received anonymously.
- of the signed reports, two were made by external Stakeholders, one relating to poor service suffered by a customer, and one concerning a complaint made by a supplier. It remains objectively impossible to confirm whether there were further reports made by external Stakeholders, given that some complaints were made anonymously, as specified.
Generally, the matters reported concerned, in almost all cases, alleged irregular conduct by employees or managers and, in the remaining cases, alleged poor service to customers and suppliers.
Of the 23 reports received by the end of 2014, at the start of 2015 three are in the process of verification and analysis, while twenty have been fully dealt with. With regard to the latter group, specific checks were made, involving, where necessary, the relevant company departments.
Based on the analyses carried out, and the documentation made available, it was found that:
- in 12 cases, no objective elements with regard to such feedback were found that could confirm as true the facts alleged in the reports received;
- in the remaining 8 cases it was found that there was substantial truth to the allegations made. Specifically, these were 6 cases related to irregular conduct of employees, one case of poor after-sales service to a customer, and one case of a complaint made by a supplier. The company then acted by implementing the necessary actions relating to:
- disciplinary sanctions;
- actions to resolve the complaints received from customers/suppliers;
- internal actions to improve the Internal Control System.
In all cases, at the outcome of the investigations, the Internal Audit Department always carried out specific audits on the company processes involved in the reports.
The Internal Audit Department has periodically reported, with regard to the reports received and the state of progress of the analyses carried out, to the ARSCGC, composed of independent shareholder directors, and to the Board of Statutory Auditors of Pirelli & C. S.p.A.