File a Report

You can use the present Whistleblowing platform if:

• You are performing your duties within BRT p.A. and in its subsidiaries and affiliated companies (S.D.M. Società Distributrice Merci S.r.l. a socio unico, Eurobicar S.r.l. a socio unico, S.T.A. S.r.l. a socio unico, Società Logistica Trentina S.r.l., Bartolini Corriere Espresso S.r.l. a socio unico and Fermopoint S.r.l.) – hereinafter, for brevity “BRT”; or
• You are not performing your duties within BRT but you wish to file an alert about a situation related to your relationship with BRT.

If you belong to one of the categories above, you can file an alert about:

• conducts or situations contrary to the values and principles defined in BRT Code of Conduct, in the 231 Organizational Models and/or in Geopost Sustainable Procurement Charter, to the applicable laws and regulations and/or to the policies and procedures of BRT and/or of Geopost;
• a crime or offence;
• a threat or harm to the public interest;
• a breach or attempted cover-up of a breach of an international undertaking, law, or regulation; or
• serious violations of human rights and fundamental freedoms, the health and safety of people and the environment.

Once your alert is filed, it is handled in several stages, under the responsibility of the Ethics Officer of BRT and of any other person authorised to handle alerts within BRT.

You’ll be able to access it once submitted, for further follow-up.

To do so:

• • A username and a password are displayed on the screen once you have submitted your alert. Please save them securely to create an account and be able to connect to the platform thereafter;
  • If you choose to identify yourself and to share your mail address, you’ll receive this information by e-mail as well.

Step 1 – Entering of the information related to the alert into the platform:

The information you share are entered into the present platform.

For your alert to be handled and investigated, it’s important to describe the facts you wish to report as accurately, clearly and in as much detail as possible, to provide factual information and supporting your alert with any evidence proving the aforementioned facts (for example: letters, mails, SMS, etc.).

Step 2 – Receiving the alert and sending an acknowledgment of receipt:

• • Your alert is first read by Safecall, to make sure the information you provided are complete.
    As part of this first reading, Safecall may need to contact you to ask for additional information if needed.

• • The Ethics Officer of BRT and/or any person authorised to handle alerts within BRT is informed by Safecall that an alert has been created.

• • You’ll receive from the Ethics Officer of BRT or any person authorised to handle alerts within BRT an acknowledgment of receipt, within 7 days of receipt of the alert maximum.

Step 3 – Admissibility Analysis of the alert:

For your alert to be deemed admissible:

• • You belong to one of the categories of persons who can file alerts and your alert relates to one of the topics as provided for by the present whistleblowing platform.
    For more information on the above, please refer to the answer to question Who can file an alert? What topics can I report about?
  • You must provide sufficiently precise, clear and detailed information and include the elements necessary for its analysis (e.g. letters, e-mails, SMS, etc.);
  • Your alert must be based on evidence that can be verified and considered reliable (and not on suspicion or vague rumours); and

Step 4 – Conducting an investigation when the alert is admissible:

When the alert is qualified as admissible, an investigation is conducted to verify the facts relating to the alert and whether it is confirmed by established evidence.

The investigation is conducted by the Ethics Officer of BRT and by one or more persons authorised to handle alerts within BRT, appointed by BRT.

Step 5 – Follow-up on the handling of the alert with the whistleblower

Throughout the handling process, you’ll be informed on the progress of your alert by the Ethics Officer of BRT or by any other person authorised to handle alerts within BRT.

The follow-up can be done either through the secured messaging service of the present platform, or according to your preferred contact method.

Step 6 – Closing the alert

Once your alert has been analysed to determine its admissibility and investigated, if applicable, you will be informed of its closure in writing by the Ethics Officer of BRT or by any other person authorised to handle alerts within BRT, within 90 days of the sending of the acknowledgement of receipt (see step 2).

Depending on the situation, you will be informed of the actions taken resulting from your alert, the measures taken to remedy the facts reported, or the reasons why your alert is considered non admissible, where appropriate.

The personal data collected are subject to processing, which responsible is BRT S.p.A. (hereinafter referred as “BRT”), with registered office in Foro Buonaparte no. 67, 20121, Milan (MI), Italy, and administrative office in Via Enrico Mattei no. 42, 40138, Bologna (BO), Italy, acting as Data , within the meaning of the General Data Protection Regulation.

The personal data are collected also by Safecall Limited, RTC Loftus House, Colima Avenue, Sunderland, SR5 3XB, UK, acting as Data Controller. Here you can find Safecall privacy notice:  https://www.safecall.co.uk/en/privacy-policy-whistleblowing/

The purpose of the processing of personal data is:

• Reception and entering of whistleblowing alerts;
• Investigation and alert follow-up;
• Development of activity data (statistical) from anonym data.

The lawfulness for this processing is based on a legal obligation regarding whistleblowing systems, provided by Legislative Decree no. 24 dated 10^th March 2023 regarding “Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law”,  by Law no. 179 dated 30^th of November 2017 regarding “Provisions to protect people reporting crimes or irregularities they become aware in the context of a public or private employment relationship” and by Legislative Decree no. 231 dated 8^h of June 2001 regarding “Regulation of the administrative liability of legal entities, companies and associations”.

Personal data are also processed based on the legitimate interest of BRT, to handle whistleblowing alerts in case of situations contrary to BRT Code of Conduct, to the 231 Organizational Models, to Geopost Sustainable Procurement Charter, to applicable laws and regulations and/or to the policies and procedures of BRT and/or Geopost.

These data will be kept for:

• 30 days after receiving the alert if it’s not admissible;
• 2 months after closing the alert if it’s admissible but doesn’t result into any disciplinary or legal actions;
• 2 months after the decision taken following the investigation if the alert results into disciplinary or legal actions unless further retention is legally requested by the proceedings.

The use of the Whistleblowing system is optional.

However, when it’s used, the alert may contain personal data necessary to qualify the facts and to allow BRT to handle the alert pursuant to the legal and regulatory obligations and the whistleblowing procedure of BRT.

The data processed by BRT are shared through the Safecall tool following your alert on their online platform or via their phone line.

You can choose the level of anonymity of your alert.

Depending on it, Safecall will only share with BRT the information on your identity you accept BRT knows.

The recipients of the processed personal data shared through the Whistleblowing system are the Ethics Officer of BRT or any person authorised to handle alerts within BRT, as well as, as part of the rights of the defence, the person concerned by the alert.

You have the following rights on your personal data:

• Right of access, of rectification and of limitation;
• Right to erasure of all your personal data when the alert is related to a breach of BRT Code of Conduct and/or to the policies and procedures of BRT and Geopost
• Right of opposition to the processing of all your personal data when the alert is related to a breach of BRT Code of Conduct and/or to the policies and procedures of BRT and Geopost unless:

• • if there are legitimate and imperatives motives prevailing on the data subject’s rights; or
  • if the processing is necessary for the recognition, exercise, or defence of a right.

• Right to give instructions related to the retention, erasure and sharing of your data after your death.

These rights may be exercised by sending an e-mail to privacy@brt.it  

The Data Protection Officer of BRT can be contacted by sending an e-mail to dpo@brt.it

Some of your personal data are transferred to the United Kingdom where Safecall datacenters are located.

United Kingdom is considered as an adequate country, guaranteeing a sufficient level of protection of personal data.

If you believe, after having contacted us, that your rights with regard to your data have not been respected, you may submit a complaint to the following Data Protection Authority: https://www.garanteprivacy.it/home

You also have the possibility to file an alert by calling the Safecall phone line.

To do so:

• Please call the following number 00 800 7233 2255  if you’re located in Italy.

If you’re located in another country, please refer to the list of Safecall hotline numbers available here: https://www.safecall.co.uk/en/file-a-report/telephone-numbers/

This number is free of charge and available 24/7.

• Please choose the language in which you wish to file your alert.
• If you wish to file your alert in Italian, you’ll be put in contact almost immediately with a Italian-speaker.
• You’ll be able to confidentially discuss with the Italian-speaker contact person on the details of your alert, by answering their questions.